{"meta":{"key":"s_sc--pass-03","task":"S_SC","title":"SSC South Carolina consumer agreements and client-money duties","parent_title":"South Carolina debt and debt relief law","edition":"pass-03","path":"/research/s_sc--pass-03/","kind":"split_pass","category":"state","role":"state","area_numbers":[66],"groups":["collections"],"date":"2026-10-24","tables":3,"claims":50,"sources":13,"review_status":"revise","review_complete":true,"sha256":"c442baa5eed0f3ad19dfacbef6411cd87ba8a111dcc67e024171a2e048819322","headings":["Executive result","A1. Mandatory agreements for negotiation versus DMP/credit-counseling models","A1.1 Coverage necessary to apply the agreement duties","A1.2 Pre-contract prerequisites","A1.3 Written contract and execution","A1.4 General mandatory contract provisions","A1.5 Additional DMP / creditor-distribution terms","A1.6 Creditor consent records","A1.7 Contract copy and delivery","A1.8 Readability, completeness, and prohibited terms","A2. Electronic execution, electronic delivery, and consent limits","A3.1 Continuous cancellation right, not a fixed cooling-off window","A3.2 Written notice and method","A3.3 Legal counting rule: exact calendar endpoint held","A3.4 What must be refunded","Refund timing","A4.1 Trigger for the statutory trust-account regime","A4.2 Trust and segregation duties","A4.3 Deposit deadline","A4.4 Creditor disbursement deadline","A4.5 Consumer receipts and access","A4.6 Monthly reconciliation","A4.7 Quarterly accounting and demand accounting","A4.8 FDIC-insured institution language","A4.9 Third-party account administrators","A4.10 Records and retention","Statute","Regulation","Agency interpretations and guidance","Example 1 — Compensated negotiation, consumer retains all settlement money","Example 2 — $600 received for creditor distribution","Example 3 — Cancellation after some creditor money has already been spent","Example 4 — Monthly reconciliation","Case A — bank cash = $500","Case B — bank cash = $490","Example 5 — Quarterly accounting arithmetic","Example 6 — Ten-day cancellation: exact calendar date intentionally held","Example 7 — Conditional §109 setup refund without importing an old fee amount","Example 8 — Third-party “special purpose account”","Actually read in this pass","Explicitly not established"],"generation_provenance":{"actual_route":"regular_chat_adaptive_models","actual_model":"GPT-5.6 Sol","actual_mode":"Medium","provenance_limit":"Actual documented capture labels only; missing labels remain unknown. No preferred setting is inferred as actual execution."},"public_id":"S_SC/pass-03","facets":{"geography":["us","us-sc"],"debt_type":[],"stage":[],"subject":["agreements-disclosures","client-money"]},"scope":"Independent required agreements/cancellation/client-money custody component; prior fee/source holds remain open.","pending_corrections":0},"markdown":"# S_SC PASS-03 — South Carolina consumer agreements and client-money duties\n\n**SettleADebt.com extensive state investigation — South Carolina**\n**Current-source check:** October 24, 2026, Pacific\n**Actual research/access date:** October 24, 2026, Pacific\n\nThis is a **focused contract/client-money component only**. It does not complete South Carolina, does not establish that SettleADebt.com or any provider is authorized, and does not convert unresolved PASS-01/PASS-02 issues into settled law.\n\n## Executive result\n\nSouth Carolina draws a consequential line between a **compensated noncustodial negotiation service** and a **custodial/control-based debt management plan**.\n\nA compensated provider negotiating reductions of obligations can be within Chapter 7 even when it never takes possession of settlement money. Such a provider is subject to the Act's general pre-service education/budget-analysis and written-contract requirements if no exemption applies. But the additional statutory provisions concerning schedules of money sent to the organization for creditor distribution, participating/nonparticipating creditor lists, and the §37-7-111 trust-account regime are directed to the DMP/funds-distribution model. DCA's own current counseling checklist expressly separates the general contract requirements from the additional provisions applicable when the organization receives consumer money for creditor disbursement. [South Carolina Legislature+1](https://www.scstatehouse.gov/code/t37c007.php)\n\nFor money actually paid to the licensee for creditor distribution, South Carolina imposes a substantial custody regime: a trust account for debtors' benefit, debtor-by-debtor account records, deposit within **one business day**, creditor disbursement within **five business days**, continuous segregation, monthly reconciliation, quarterly accounting, and a consumer accounting within **seven days after written demand**, subject to a frequency limit. [South Carolina Legislature](https://www.scstatehouse.gov/code/t37c007.php)\n\nThe cancellation right is not a conventional three-day cooling-off period. The required contract disclosure says the consumer may cancel **at any time and for any reason**, without penalty or obligation, by giving **10 days' written notice**; §37-7-110(D) separately requires cancellation of a DMP upon the consumer's request with at least ten days' notice and refund of all **unexpended funds**. South Carolina Chapter 7 does not supply a counting rule in the provisions reviewed that safely converts “10 days” into a specific calendar endpoint, so this pass does not invent one. [South Carolina Legislature](https://www.scstatehouse.gov/code/t37c007.php)\n\n# A. Substantive answers\n\n## A1. Mandatory agreements for negotiation versus DMP/credit-counseling models\n\n### A1.1 Coverage necessary to apply the agreement duties\n\nSouth Carolina's statutory definition of credit-counseling services includes three distinct types of conduct: receiving or offering to receive consumer money for creditor distribution; improving or offering to improve credit; and negotiating or offering to negotiate deferral or reduction of obligations concerning credit extended by others. A “debt management plan” is narrower: it involves settlement/pooling/distribution **and** the consumer giving the organization money or control of funds for distribution to creditors. “Debt settlement” includes forgiveness of principal or reduction in payments, charges, or fees. **S_SC-P3-C001–C002.** [South Carolina Legislature](https://www.scstatehouse.gov/code/t37c007.php)\n\nAccordingly:\n\n- **Noncustodial settlement/negotiation:** Chapter 7 can apply even if the consumer keeps settlement money and pays creditors directly.\n- **Custodial/control DMP:** additional duties attach where the consumer gives the organization money or control of funds for creditor distribution.\n- Calling a product “debt settlement,” “credit counseling,” “legal services,” or a “special-purpose account” does not itself decide which branch applies. Actual services and control matter. **C002.**\n\nThe Act's geographic nexus is broad enough to reach an organization that solicits or contracts with South Carolina debtors even without a South Carolina office. **C003.** [South Carolina Legislature](https://www.scstatehouse.gov/code/t37c007.php)\n\nChapter 7's exclusions remain conditional. Among others, it lists South Carolina-authorized attorneys acting in the regular course of their profession, specified financial institutions, CPAs in an accounting practice, certain court actors, nonprofit **faith-based** organizations, and other enumerated categories. Nothing in this pass treats a generic nonprofit label, attorney affiliation, or bank relationship as sufficient. **C004.** [South Carolina Legislature](https://www.scstatehouse.gov/code/t37c007.php)\n\n### A1.2 Pre-contract prerequisites\n\nBefore covered credit-counseling services or a DMP are undertaken, §37-7-108 requires:\n\n1. the statutory credit-education program;\n2. a written, thorough budget analysis;\n3. delivery of a copy of that budget analysis to the debtor;\n4. a determination that the proposed program is suitable and that the debtor can reasonably meet the budget; and\n5. a separate written disclosure that the consumer may keep, displayed clearly and conspicuously and containing **nothing else**.\n\nThe required disclosure warns that the services may not be suitable for all consumers and that alternatives, including bankruptcy, may be available. It also contains a secured-debt limitation/warning unless such services are offered. **C005.** [South Carolina Legislature](https://www.scstatehouse.gov/code/t37c007.php)\n\nThe budget analysis itself is prescriptive. It includes income, deductions, housing and living expenses, garnishments/judgments, creditors reasonably expected to participate and not participate, and the amount available for the DMP. [South Carolina Legislature](https://www.scstatehouse.gov/code/t37c007.php)\n\nDCA's 2010 Administrative Interpretation 7.108-1001 further interprets the budget-analysis process as work that must be performed/completed by properly licensed counselors in the circumstances addressed there; it rejected use of unlicensed counselors to gather the statutory §108(2)(a)–(m) information while awaiting licensure. That is an **agency interpretation**, not a statute or judicial holding. **C006.** [Consumer Affairs+1](https://www.consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1001%20Credit%20Counselor%20-%20Budget%20Analysis.pdf)\n\n### A1.3 Written contract and execution\n\nSection 37-7-110(A) provides that a credit-counseling service requiring payment, a fee, or other consideration may not be supplied unless there is a **written and dated contract**, compliant with subsections (B) and (C), signed by the consumer. The statute expressly says this section does not apply to the §37-7-109(A) setup fee. The precise interaction between that exception and the regulation's fee-in-contract rule remains an earlier-pass unresolved issue and is **not resolved in PASS-03**. **C007.** [South Carolina Legislature](https://www.scstatehouse.gov/code/t37c007.php)\n\nDCA's 2010 Interpretation 7.108-1003 independently confirms the agency's construction that the education program, budget analysis, and compliant written contract precede compensated covered counseling services. It also addresses assignments of existing contracts. Again, this is an agency administrative interpretation, not controlling statutory text or a judicial holding. **C008.** [Consumer Affairs+1](https://www.consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf)\n\n### A1.4 General mandatory contract provisions\n\nThe contract must include, among other things:\n\n- consumer and licensee names, addresses, and telephone numbers;\n- a reasonable estimate of **all payments and fees** the consumer will make to the organization during the contract, including a maximum;\n- a full and detailed description of services;\n- all guarantees;\n- an estimated completion date or performance period, which cannot exceed five years from the original contract;\n- the statutory cancellation statement;\n- required disclosures concerning possible creditor compensation;\n- the restriction on required ancillary products/services in the DMP context;\n- the prohibition on mandatory “voluntary contributions”; and\n- Department contact information. **C009.** [South Carolina Legislature+1](https://www.scstatehouse.gov/code/t37c007.php)\n\nThis pass does **not** recalculate or reassess the fee ceilings from PASS-01. The contract must disclose whatever fees are lawfully applicable, but contract disclosure cannot itself create a fee otherwise unauthorized by law.\n\n### A1.5 Additional DMP / creditor-distribution terms\n\nWhere the arrangement involves funds being sent to the organization for creditor distribution, additional terms include:\n\n- a schedule of payments to be made by the consumer to the organization for creditor distribution, including amount and due date;\n- late/default terms;\n- creditors expected to participate;\n- a good-faith belief at contract execution that the identified creditors will participate;\n- notice to the consumer of changes in creditor acceptance within **two business days after learning of the change**;\n- for each participating creditor, the debt amount, payment amount, payment date, and anticipated payoff date;\n- identification of creditors not expected to participate. **C010.** [South Carolina Legislature](https://www.scstatehouse.gov/code/t37c007.php)\n\nDCA's current foreclosure/housing counseling compliance checklist is particularly useful here because it divides contract requirements into general requirements and additional terms **“if receiving consumer money for disbursement to creditors.”** That operational guidance supports—not replaces—the textual distinction between ordinary compensated negotiation and a custodial DMP. **C011.** [Consumer Affairs](https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Regulatory/Credit%20Counseling/Forms/Foreclosure%20Counseling%20Guidance.pdf)\n\n### A1.6 Creditor consent records\n\nFor a DMP, §37-7-109 requires a separate creditor-consent record maintained in the debtor file. It must identify all creditors and document how and when consent was sought, whom the provider contacted where available, responses, special/revised conditions, and when required consent was secured. The statute permits seeking consent by telephone, fax, electronic mail, or first-class mail. It establishes statutory presumptions after specified periods when a creditor does not respond or when it accepts a DMP payment. **C012.** [South Carolina Legislature](https://www.scstatehouse.gov/code/t37c007.php)\n\nDCA's currently posted FAQ goes further procedurally: it says the creditor-consent form itself must be **on paper** and kept in the client's paper file; if the underlying information is held electronically, a compliant table should be printed and placed in that file. That is agency operational guidance rather than the enacted text and should not be elevated to a statutory electronic-record prohibition. **C013.** [Consumer Affairs](https://consumer.sc.gov/consumer-faqs/credit-counseling-faqs?utm_source=chatgpt.com)\n\n### A1.7 Contract copy and delivery\n\nThe Act explicitly requires delivery to the consumer of:\n\n- a copy of the written budget analysis; and\n- the separate §37-7-108(3) disclosure **in a form the consumer may keep**.\n\nBy contrast, in the Chapter 7 provisions and R.28-700 passages actually reviewed in this pass, I did **not** locate an express clause saying, in those words, that the organization must deliver a copy of the fully executed §37-7-110 contract to the consumer. The regulation requires the organization to retain documents signed by and/or given to the consumer, expressly including the budget analysis and contract, but that retention rule does not itself create a new delivery command. **C014.** [South Carolina Legislature+1](https://www.scstatehouse.gov/code/t37c007.php)\n\nTherefore:\n\n**HOLD:** do not assert either that no executed-copy duty exists under all South Carolina law or that email/hand delivery of an executed copy is mandatory under Chapter 7 until any generally applicable contract/e-commerce law or later DCA authority addressing that point is checked.\n\n### A1.8 Readability, completeness, and prohibited terms\n\nNo general font-size, grade-level, or plain-language formula was located in the Chapter 7/R.28-700 provisions reviewed. But the statute has several specific presentation controls:\n\n- the §108(3) warning must be **clear and conspicuous**, in a separate written document that the consumer can keep and that contains nothing else;\n- the cancellation language must be **bold face**, conspicuous, and immediately proximate to the consumer's signature;\n- a provider may not present a contract or other agreement for signature unless it has been fully filled in and completed. **C015.** [South Carolina Legislature+1](https://www.scstatehouse.gov/code/t37c007.php)\n\nChapter 7 also prohibits obtaining a consumer's waiver of rights under the chapter, using specified mandatory ancillary purchases, charging a DMP rescission fee, using unfair/deceptive contract terms, and collecting payment before earned as specifically defined in the contract. A violation of §37-7-116 renders the agreement between the licensee and consumer **void**. That voidness rule is directly relevant to agreement validity; broader remedies are reserved for later passes. **C016.** [South Carolina Legislature](https://www.scstatehouse.gov/code/t37c007.php)\n\n## A2. Electronic execution, electronic delivery, and consent limits\n\nSouth Carolina's Uniform Electronic Transactions Act provides the general state-law framework.\n\nAn electronic record or signature cannot be denied legal effect solely because it is electronic; an electronic record can satisfy a writing requirement and an electronic signature can satisfy a signature requirement. But the Act applies only when the parties have agreed to conduct the transaction electronically. A party is not automatically required to transact electronically merely because another party prefers it. **C017.** [South Carolina Legislature](https://www.scstatehouse.gov/code/t26c006.php)\n\nWhere another law requires information to be provided, sent, or delivered in writing, an electronic record can satisfy that requirement only if it is capable of retention by the recipient when received. A sender cannot inhibit the recipient's ability to print or store the record, and any other statutory formatting or transmission requirements continue to apply. **C018.** [South Carolina Legislature](https://www.scstatehouse.gov/code/t26c006.php)\n\nThis supports the following bounded conclusions:\n\n- A §37-7-110 contract is not invalid merely because it uses an electronic record/signature, assuming UETA's party-agreement requirements and all other statutory requirements are met.\n- A required disclosure that must be in a form the consumer can keep cannot safely be implemented as an ephemeral screen that the consumer cannot retain.\n- Electronic form does not excuse the statutory placement, conspicuousness, or content restrictions.\n- The separate DCA procedural instruction that the DMP creditor-consent form be kept on paper remains a distinct administrative requirement. **C013, C017–C019.**\n\nSouth Carolina's UETA expressly preserves the federal E-SIGN Act's §101(c) consumer-disclosure framework rather than superseding it. This PASS-03 did **not** perform a full fresh 2026 federal E-SIGN investigation, so an electronic consumer-consent implementation requiring federal §101(c) compliance remains an exact implementation dependency. **C019.** [South Carolina Legislature](https://www.scstatehouse.gov/code/t26c006.php)\n\n# A3. Cancellation, termination, refunds, and deadlines\n\n## A3.1 Continuous cancellation right, not a fixed cooling-off window\n\nThe mandatory contract language must tell the consumer that the consumer:\n\n- may cancel **without penalty or obligation**;\n- may do so **for any reason**;\n- may do so **at any time**;\n- does so by providing **10 days' written notice of rescission**; and\n- after services are canceled, is entitled to a refund of all **unexpended funds** paid to the organization. **C020.** [South Carolina Legislature](https://www.scstatehouse.gov/code/t37c007.php)\n\nSection 37-7-110(D) separately commands the licensee to cancel a DMP upon the consumer's request for any reason and at any time, with the consumer providing at least ten days' notice, followed by a full refund of all unexpended funds paid to the licensee. **C021.** [South Carolina Legislature](https://www.scstatehouse.gov/code/t37c007.php)\n\nThis is better described as a **continuing termination right with notice**, not a conventional three-day or seven-day cooling-off period. **C022.**\n\n## A3.2 Written notice and method\n\nThe mandatory contractual statement expressly requires **written** notice. The Act does not, in the cancellation clauses reviewed, enumerate postal mail, personal delivery, fax, or email as the required method.\n\nSouth Carolina UETA can make an electronic record a writing where its requirements apply, but whether a particular email, portal message, or click-based cancellation satisfies the contract and all consumer-consent rules depends on the transaction's agreed electronic framework. **C023.** [South Carolina Legislature](https://www.scstatehouse.gov/code/t26c006.php)\n\nA provider therefore should not infer from §37-7-109's express authorization of email for **creditor consent** that the same statutory list automatically governs **consumer cancellation**. They are different provisions.\n\n## A3.3 Legal counting rule: exact calendar endpoint held\n\nChapter 7's cancellation provisions say “10 days” / “at least ten days” but the provisions reviewed in PASS-03 do not supply a specific private-contract counting rule stating, for example, whether:\n\n- the notice date is included or excluded;\n- receipt or transmission starts the period;\n- weekends or holidays are counted;\n- the cancellation becomes effective at the beginning or end of the tenth day.\n\nSouth Carolina Rule of Civil Procedure 6 contains a time-computation system for litigation/procedural deadlines, but this pass found no authority making that court-procedure rule the counting rule for a private Chapter 7 cancellation notice. It is therefore **not imported here.**\n\n**C024: No exact calendar cancellation endpoint is claimed without further authority plus actual delivery facts.**\n\n## A3.4 What must be refunded\n\nThe statutory cancellation measure is **all unexpended funds paid to the licensee**. It does not say “refund every amount the consumer has ever paid,” and it should not be silently converted into a refund of creditor payments already disbursed or every previously earned lawful fee. **C025.** [South Carolina Legislature](https://www.scstatehouse.gov/code/t37c007.php)\n\nSeparate rules must remain separate:\n\n1. **Unexpended client funds:** refunded on cancellation under §110.\n2. **Conditional DMP setup-fee refund:** §109(A) requires return of the setup fee and account closure if, within the statutory 45-day condition, creditor nonconsent makes the plan unsuitable.\n3. **Unlawfully received money:** R.28-700 separately requires return to the payor of money received in violation of the Act or regulation.\n4. **Already disbursed creditor money:** is not “unexpended” merely because the consumer later terminates.\n5. **Earned lawful provider compensation:** is not automatically converted by §110(D)'s language into unexpended creditor money. Whether a disputed fee was lawfully earned remains a separate question. **C025–C027.** [South Carolina Legislature+1](https://www.scstatehouse.gov/code/t37c007.php)\n\n### Refund timing\n\nSection 110 says that after cancellation the consumer is entitled to the refund, but the provisions reviewed do **not** specify an independent “within X days after cancellation” payment deadline for the unexpended-funds refund.\n\n**C028: exact refund-payment deadline remains held.**\n\nThat is different from §111's explicit time requirements for depositing and disbursing creditor funds.\n\n# A4. Client-money custody, control, accounts, and records\n\n## A4.1 Trigger for the statutory trust-account regime\n\nSection 37-7-111 says that funds paid by or on behalf of a consumer to a licensee **for disbursement to the consumer's creditors** must be deposited into a trust account established by the licensee for the benefit of debtors. **C029.** [South Carolina Legislature](https://www.scstatehouse.gov/code/t37c007.php)\n\nThis is an actual money-flow trigger.\n\nA truly noncustodial negotiation arrangement—consumer retains the settlement funds and pays creditors directly—does not become subject to §111's deposit rule merely because the provider negotiates. The provider can still be covered by Chapter 7 as a negotiation service; it simply has not received the particular funds described by §111. **C030.** [South Carolina Legislature+1](https://www.scstatehouse.gov/code/t37c007.php)\n\nBut “noncustodial” cannot be assumed from branding. The DMP definition expressly includes giving the organization **control of funds**, not only physical receipt. If a provider or its agent can direct, restrict, or cause distributions from an account, the actual control arrangement requires analysis before classifying the model as noncustodial. **C031.** [South Carolina Legislature](https://www.scstatehouse.gov/code/t37c007.php)\n\n## A4.2 Trust and segregation duties\n\nFor funds within §111:\n\n- the licensee establishes the trust account for debtors' benefit;\n- separate account records must be kept for each debtor;\n- debtor money must at all times remain separate from the funds of the licensee and its officers, employees, and agents;\n- debtor funds may not be used for purposes other than paying the debtor's bills, invoices, and accounts. **C032.** [South Carolina Legislature](https://www.scstatehouse.gov/code/t37c007.php)\n\nThis pass does **not** interpret the last clause as affirmative authorization to deduct any particular provider fee from trust funds. The quarterly accounting provision separately requires reporting “charges deducted,” but that accounting language does not by itself establish that every otherwise lawful fee can be removed from the trust balance. **C033 — HOLD on precise provider-fee deduction mechanics.**\n\n## A4.3 Deposit deadline\n\nThe licensee must deposit a debtor's payment into the trust account **no later than one business day after receipt**. **C034.** [South Carolina Legislature](https://www.scstatehouse.gov/code/t37c007.php)\n\nThis is a business-day deadline, not a one-calendar-day rule.\n\n## A4.4 Creditor disbursement deadline\n\nFunds received for creditor distribution must be disbursed to creditors **no later than five business days after receipt**. **C035.** [South Carolina Legislature](https://www.scstatehouse.gov/code/t37c007.php)\n\nThe provider also bears responsibility for correcting payments misdirected because of its own error. **C036.**\n\nThese provisions materially constrain any model in which the provider plans to accumulate creditor-payment money for an extended period.\n\n## A4.5 Consumer receipts and access\n\nUpon request, the licensee must provide either signed, dated receipts for money received under the DMP or an electronic means by which the consumer can obtain the account status. **C037.** [South Carolina Legislature](https://www.scstatehouse.gov/code/t37c007.php)\n\nThis provision permits electronic account-status access; it is distinct from the paper creditor-consent instruction discussed above.\n\n## A4.6 Monthly reconciliation\n\nThe licensee must reconcile each trust account at least monthly by comparing:\n\n- the actual cash balance; against\n- the total of the individual escrow balances for each debtor.\n\nEach trust account must be separately scheduled and reconciled. **C038.** [South Carolina Legislature](https://www.scstatehouse.gov/code/t37c007.php)\n\nThe text requires reconciliation but, in the passages reviewed, does not prescribe a specific numerical tolerance or a separate cure period for an unexplained shortfall. A discrepancy therefore cannot simply be treated as acceptable because it is small.\n\n## A4.7 Quarterly accounting and demand accounting\n\nAt least quarterly, the consumer accounting must show:\n\n- total funds received;\n- total paid to each creditor;\n- the total each creditor agreed to accept in full satisfaction;\n- charges deducted; and\n- the amount held in trust. **C039.** [South Carolina Legislature](https://www.scstatehouse.gov/code/t37c007.php)\n\nOn written demand, an accounting must be provided within **seven days**, although the licensee need not provide more than three such accountings during each six-month period. **C040.** [South Carolina Legislature](https://www.scstatehouse.gov/code/t37c007.php)\n\nAgain, without an established private-law counting rule and actual receipt facts, this pass does not convert “within seven days after written demand” into an exact calendar date.\n\n## A4.8 FDIC-insured institution language\n\nR.28-700's recordkeeping section requires the organization to maintain the name and address of the **FDIC-insured institution where South Carolina consumer funds are held**, together with the account number. **C041.** [South Carolina Legislature](https://www.scstatehouse.gov/coderegs/Chapter%2028.pdf)\n\nThis is consequential but should be described carefully: the provision is drafted as a **recordkeeping requirement**, not as a standalone sentence saying “all trust accounts must be at an FDIC-insured institution.” Its wording nevertheless presupposes an FDIC-insured institution for the identified South Carolina consumer funds.\n\nI therefore treat:\n\n**Use of an FDIC-insured institution as strongly supported by the operative regulation's required records, but do not recast the recordkeeping clause into broader account-eligibility language the regulation itself does not use.**\n\n## A4.9 Third-party account administrators\n\nNeither §37-7-111 nor the R.28-700 passages reviewed in this pass supplied a general authorization saying a licensed provider may outsource its statutory trust-account custody duties to an unaffiliated third-party administrator.\n\nA third-party arrangement therefore presents at least three separate questions:\n\n1. Who legally owns the funds?\n2. Who actually has authority/control over withdrawals and distributions?\n3. Is the third party acting as the licensee's agent or independently?\n\nIf the provider retains control, merely placing the account in another entity's name does not establish noncustodial treatment. If the consumer alone owns and controls the account, §111's “funds paid … to a licensee for disbursement” trigger may not apply to that account—but other law may.\n\n**C042: third-party custody/control authority remains unresolved and cannot be inferred from the counseling license.**\n\n## A4.10 Records and retention\n\nSection 37-7-114 requires complete and accurate books, accounts, and records and calls for retention of specified DMP-related records for at least **three years after termination of the DMP**. Records include consumer information, agreements/extensions, payments, disbursements, charges, and correspondence. Out-of-state records must be made available to DCA within the statutory time when demanded for examination. **C043.** [South Carolina Legislature](https://www.scstatehouse.gov/code/t37c007.php)\n\nR.28-700 adds detailed recordkeeping requirements, including:\n\n- documents signed by and/or provided to consumers, including the budget analysis and contract;\n- creditor-consent documentation;\n- trust-account statements;\n- the financial-institution/account information discussed above;\n- additional business and consumer records.\n\nThe regulation requires consumer records for at least **three years after termination of the contract** and provides retention rules for business records tied to discontinuation of the relevant account, script, advertisement, contract, record, or complaint. It allows electronic data-processing systems or electronic duplicates when they provide equivalent information and remain accessible, subject to the specific DCA paper creditor-consent guidance already noted. **C044.** [South Carolina Legislature](https://www.scstatehouse.gov/coderegs/Chapter%2028.pdf)\n\n# A5. Enactment, adoption, effective, and current-status reconciliation\n\n## Statute\n\nThe Consumer Credit Counseling Act originated in **Act 111 of 2005 / S.607**. The legislature's history shows the Act became law without the Governor's signature on June 2, 2005, with an effective date of **December 2, 2005**. **C045.** [South Carolina Legislature](https://www.scstatehouse.gov/query.php?category=LEGISLATION&conid=6815778&keyval=1160607&numrows=100&result_pos=1500&search=DOC&searchtext=do%25&session=0)\n\nThe South Carolina Legislature's online Code states that it is current through the **2026 legislative session**, while also warning that the online compilation is not the official printed Code. That supports current statutory use here with the site's stated publication limitation. **C046.** [South Carolina Legislature](https://www.scstatehouse.gov/code/statmast.php)\n\n## Regulation\n\nThe currently posted R.28-700 history states:\n\n- added effective May 26, 2006;\n- amended effective June 26, 2009;\n- amended effective February 26, 2016. **C047.** [South Carolina Legislature](https://www.scstatehouse.gov/coderegs/Chapter%2028.pdf)\n\nThe Legislature's regulation-status page, however, says its online regulation compilation is current through **State Register Volume 50, Issue 3, effective March 27, 2026**. [South Carolina Legislature](https://www.scstatehouse.gov/coderegs/statmast.php)\n\nFor this PASS-03 I independently checked the **October 23, 2026 State Register, Volume 50 Issue 10**. It contains no DCA/Chapter 28/credit-counseling amendment in its contents, and targeted searches returned no R.28-700/credit-counseling change. [South Carolina Legislature+3](https://www.scstatehouse.gov/state_register.php?file=Sr50-10.pdf&first=FILE&pdf=1)\n\nBut I did **not** freshly reread every April–September 2026 issue in PASS-03. Because the user expressly instructed me not to adopt the prior-pass currentness conclusion as verified law, the proper PASS-03 status is:\n\n**C048: R.28-700 is the operative text shown in the official online compilation through March 27, 2026; no relevant change appears in the independently checked October 23 issue; the April–September 2026 intervening Register history is not independently reverified in this pass and remains a currentness dependency rather than being silently borrowed from PASS-01/PASS-02.**\n\n## Agency interpretations and guidance\n\nDCA's 7.108-1001 and 7.108-1003 are dated **April 15 and June 29, 2010**, respectively. DCA's current Chapter Seven index continues to post them, but expressly warns that interpretations may be superseded and should be confirmed before formal reliance. They are not regulations, judicial holdings, or formal adjudicatory orders. **C049.** [Consumer Affairs](https://www.consumer.sc.gov/business-resourceslaws/administrative-interpretations/chapter-seven)\n\nDCA's foreclosure counseling checklist and FAQ are **agency procedural/compliance guidance**. They are useful evidence of the Department's operating interpretation, but they do not displace statutory or regulatory text. **C050.** [Consumer Affairs+1](https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Regulatory/Credit%20Counseling/Forms/Foreclosure%20Counseling%20Guidance.pdf)\n\n# B. PASS-03 source table\n\nAll sources below were actually accessed or freshly reused on **October 24, 2026 Pacific**. Direct destinations are supplied as source links because this interface renders web destinations as safe link objects rather than exposed raw URL strings.\n\n| Source ID | Issuer / title | Direct source | Exact passage/read | Legal/status characterization and limitations |\n| --- | --- | --- | --- | --- |\n| **S_SC-P3-S001** | South Carolina General Assembly — Title 37, Chapter 7, Consumer Credit Counseling | [Direct Chapter 7 text](https://www.scstatehouse.gov/code/t37c007.php?utm_source=chatgpt.com) | §§37-7-101, 102, 108–111, 114, 116; especially statutory lines reflected in turn574189view0, turn186003view0, turn253842view0, turn685233view1. | Current statutory compilation through 2026 Session per S005; online compilation not official printed Code. Freshly read. |\n| **S_SC-P3-S002** | South Carolina General Assembly — Act 111 of 2005 / S.607 | [Direct enrolled-act/history page](https://www.scstatehouse.gov/sess116_2005-2006/bills/607.htm?utm_source=chatgpt.com) | Status and enactment history; became law without signature June 2, 2005; effective December 2, 2005. | Enacted historical foundation, not merely bill text. Freshly checked. |\n| **S_SC-P3-S003** | South Carolina Code of Regulations — Chapter 28, R.28-700 | [Direct Chapter 28 PDF](https://www.scstatehouse.gov/coderegs/Chapter%2028.pdf?utm_source=chatgpt.com) | R.28-700(B), (D), history; PDF pp.35–38. Page images actually inspected as turn257930view0–turn257930view2. | Operative text in online compilation; history last amendment Feb.26, 2016. Compilation-currentness limitation in S004. |\n| **S_SC-P3-S004** | South Carolina General Assembly — Code of Regulations status | [Regulation compilation status](https://www.scstatehouse.gov/coderegs/statmast.php?utm_source=chatgpt.com) | Statement that compilation is current through State Register Vol.50 Issue3, March27, 2026; online disclaimer. | Currentness boundary; intervening Apr–Sep issues not freshly re-reviewed in this pass. |\n| **S_SC-P3-S005** | South Carolina General Assembly — Code of Laws status | [Code status/disclaimer](https://www.scstatehouse.gov/code/statmast.php?utm_source=chatgpt.com) | Current through 2026 Session and online/official-print disclaimer. | Supports statutory currentness, subject to site's stated limitation. |\n| **S_SC-P3-S006** | South Carolina DCA — Foreclosure/Housing Counseling Compliance Guidance | [Direct DCA checklist PDF](https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Regulatory/Credit%20Counseling/Forms/Foreclosure%20Counseling%20Guidance.pdf?utm_source=chatgpt.com) | Contract checklist and separate “if receiving consumer money for disbursement” requirements; page image inspected as turn746933view0. | Agency guidance, expressly not a substitute for law. Useful for DCA's general-vs-custodial contract distinction. |\n| **S_SC-P3-S007** | South Carolina DCA — Credit Counseling FAQs | [DCA Credit Counseling FAQ](https://consumer.sc.gov/consumer-faqs/credit-counseling-faqs?utm_source=chatgpt.com) | Creditor-consent form and paper-file instruction. | Agency procedural guidance; no separate legal effective date located. |\n| **S_SC-P3-S008** | South Carolina General Assembly — Uniform Electronic Transactions Act, Title 26 Ch.6 | [Direct South Carolina UETA text](https://www.scstatehouse.gov/code/t26c006.php?utm_source=chatgpt.com) | §§26-6-30, 50, 70, 80: party agreement, e-record/e-signature effect, retainability, formatting, E-SIGN preservation. | Current state statute; used only for electronic-form questions. |\n| **S_SC-P3-S009** | South Carolina DCA — Administrative Interpretation 7.108-1003 | [Direct interpretation PDF](https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf?utm_source=chatgpt.com) | All 3 pages freshly inspected as page images turn780132view0–turn780132view2; prerequisite/assignment/compensation analysis. | Issued June29, 2010. Agency administrative interpretation, not regulation/court holding. Current index has supersession warning. |\n| **S_SC-P3-S010** | South Carolina DCA — Administrative Interpretation 7.108-1001 | [Direct interpretation PDF](https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1001%20Credit%20Counselor%20-%20Budget%20Analysis.pdf?utm_source=chatgpt.com) | Both pages freshly inspected as images turn780132view3–turn780132view4. | Issued April15, 2010. Same status limitation as S009. |\n| **S_SC-P3-S011** | South Carolina DCA — Chapter Seven Administrative Interpretations index | [DCA Chapter Seven interpretation index](https://consumer.sc.gov/business-resourceslaws/administrative-interpretations/chapter-seven?utm_source=chatgpt.com) | Current listing of 1001/1003 and warning regarding subsequent changes/supersession. | Current administrative index; listing ≠ formal nonsupersession determination. |\n| **S_SC-P3-S012** | South Carolina State Register Vol.50 Issue10 | [Direct October 23, 2026 issue PDF](https://www.scstatehouse.gov/state_register.php?file=Sr50-10.pdf&first=FILE&pdf=1&utm_source=chatgpt.com) | Publication metadata, contents, targeted searches for DCA/R.28-700/credit counseling; TOC page image inspected. | Published Oct.23, 2026. No relevant amendment found. Does not fill Apr–Sep PASS-03 gap. |\n| **S_SC-P3-S013** | South Carolina Supreme Court — *Lexington Law Firm v. SCDCA*, Op.26648 | [Official court opinion page](https://www.sccourts.org/media/opinions/HTMLFiles/SC/26648.htm?utm_source=chatgpt.com) | Used only as a bounded exemption cross-check: attorney category requires actual statutory conditions, not attorney branding alone. | Filed May12, 2009; controlling judicial authority on the exemption issue. No broader case-law pass performed. |\n\n# C. PASS-03 material claim table\n\n| Claim ID | Consequential assertion | Source / pinpoint | Conditions, exceptions, currentness, confidence |\n| --- | --- | --- | --- |\n| **S_SC-P3-C001** | Negotiating deferral/reduction of third-party credit obligations is independently covered conduct; receipt of client funds is not required for that category. | S001 §37-7-101(3)(c) | **High statutory text.** Compensation/entity/exemption conditions still apply. |\n| **S_SC-P3-C002** | A DMP additionally involves settlement/pooling/distribution plus consumer money or control of funds for creditor distribution. | S001 §101(6)–(7) | **High.** Actual control matters more than product label. |\n| **S_SC-P3-C003** | Soliciting or contracting with SC debtors can establish nexus without physical SC presence. | S001 §§101(2)(a), 102 | **High.** Provider-specific facts not established. |\n| **S_SC-P3-C004** | Chapter 7 exclusions are conditioned, including attorney and nonprofit-faith-based categories; labels alone do not establish exemption. | S001 §101(2)(b); S013 | **High for statutory conditions;** no entity-specific exemption determination. |\n| **S_SC-P3-C005** | Before covered counseling/DMP activity, §108 requires education, written budget analysis delivered to debtor, suitability finding, and separate retainable warning document. | S001 §108 | **High.** |\n| **S_SC-P3-C006** | DCA 7.108-1001 interprets statutory budget-analysis collection as requiring a licensed counselor in the circumstances addressed. | S010 pp.1–2 | **High as agency interpretation, not court holding/regulation.** |\n| **S_SC-P3-C007** | Compensated services generally require a written, dated consumer-signed contract before provision; §110(A) contains an express §109(A) setup-fee exception. | S001 §110(A) | **High text.** Exact setup-fee sequencing remains held from earlier work. |\n| **S_SC-P3-C008** | DCA 7.108-1003 interprets education, budget analysis, and compliant written contract as pre-service requirements for compensated counseling; assignment has conditional treatment. | S009 pp.2–3 | **High as agency interpretation.** No PASS-02 verification status assumed. |\n| **S_SC-P3-C009** | Contract must identify parties, estimate all consumer payments/fees including maximum, describe services/guarantees, and state performance period ≤5 years. | S001 §110(B)(1),(2),(4) | **High.** Does not validate any fee amount. |\n| **S_SC-P3-C010** | Custodial DMP contract provisions include consumer-to-provider creditor-payment schedule, creditor participation details and nonparticipant list. | S001 §110(B)(3),(5),(6) | **High text for DMP context.** |\n| **S_SC-P3-C011** | DCA operational guidance distinguishes general contract requirements from additional provisions when receiving consumer money for creditor disbursement. | S006 contract checklist | **Moderate/high as agency procedural interpretation; not independent legal authority.** |\n| **S_SC-P3-C012** | DMP creditor-consent record must document creditor list, solicitation method/date, responses/conditions, and consent timing. | S001 §109(B)–(D) | **High.** |\n| **S_SC-P3-C013** | DCA FAQ currently instructs that creditor-consent form be placed on paper in client's paper file even where source data is electronic. | S007 | **Agency-procedure claim only.** No statutory-paper-only rule inferred beyond that guidance. |\n| **S_SC-P3-C014** | §108 expressly requires delivery/retainability of the budget analysis/disclosure; no express executed-contract-copy delivery clause was found in reviewed Chapter7/R.28-700 text. | S001 §§108,110; S003 D(1)(a) | **Qualified negative finding.** General law or later authority may add obligations. |\n| **S_SC-P3-C015** | Specific presentation controls include clear/conspicuous standalone §108 disclosure, bold conspicuous cancellation language near signature, and fully completed agreement before signature. | S001 §§108,110,116 | **High.** No general readability metric located. |\n| **S_SC-P3-C016** | Waivers, DMP rescission fee, specified ancillary conditions, unfair/deceptive terms, and collection before earned are prohibited; §116 violation renders agreement void. | S001 §116 | **High.** Broader remedy architecture excluded. |\n| **S_SC-P3-C017** | SC UETA recognizes electronic records/signatures where parties agree to transact electronically. | S008 §§26-6-50,70 | **High state-law rule.** Other law can impose additional requirements. |\n| **S_SC-P3-C018** | Required written information can be electronic only where recipient can retain it; sender cannot inhibit printing/storage and substantive formatting requirements survive. | S008 §26-6-80 | **High.** |\n| **S_SC-P3-C019** | SC UETA preserves federal E-SIGN §101(c); exact federal consumer-consent implementation is not fully reverified in this pass. | S008 §26-6-30 | **State-law preservation high; federal implementation held.** |\n| **S_SC-P3-C020** | Mandatory contract language grants cancellation any time/any reason without penalty through 10 days' written notice, followed by refund of unexpended funds. | S001 §110(B)(7) | **High.** Exact calendar endpoint not established. |\n| **S_SC-P3-C021** | §110(D) independently requires DMP cancellation on consumer request with at least ten days' notice and refund of all unexpended funds. | S001 §110(D) | **High.** |\n| **S_SC-P3-C022** | This is a continuing termination right rather than a limited initial cooling-off window. | S001 §110(B)(7),(D) | **High textual characterization.** |\n| **S_SC-P3-C023** | Statute does not enumerate a specific cancellation transmission channel; electronic notice may qualify as writing only subject to applicable UETA/contract requirements. | S001 §110; S008 | **Qualified.** |\n| **S_SC-P3-C024** | No Chapter7 counting rule establishing an exact calendar cancellation endpoint was located; litigation Rule6 is not imported without authority. | S001 §110; targeted counting-rule review | **Hold.** |\n| **S_SC-P3-C025** | Cancellation refund is all unexpended funds, not automatically every historic payment or amount already remitted to creditors. | S001 §110(B)(7),(D) | **High for measure; earned-fee disputes remain separate.** |\n| **S_SC-P3-C026** | §109(A)'s suitability failure can separately require return of the setup fee/account closure. | S001 §109(A) | **High condition; exact fee mechanics not revisited.** |\n| **S_SC-P3-C027** | R.28-700 separately requires return of money received in violation of Act/regulation. | S003 B(4) | **Qualified currentness because Apr–Sep 2026 Register not freshly rechecked in P3.** |\n| **S_SC-P3-C028** | No separate X-day deadline for paying the §110 unexpended-funds cancellation refund was located. | S001 §110 | **Hold on payment timing.** |\n| **S_SC-P3-C029** | Funds paid to licensee for creditor disbursement must enter a trust account established for debtors' benefit. | S001 §111(B) | **High.** |\n| **S_SC-P3-C030** | Consumer-retained funds in a genuinely noncustodial negotiation model are not, solely by virtue of the negotiation, funds “paid to the licensee for disbursement.” | S001 §§101,111 | **High textual distinction;** actual account/control facts govern. |\n| **S_SC-P3-C031** | Control of funds can satisfy the DMP definition even without literal possession. | S001 §101(6) | **High.** Third-party account arrangements require factual review. |\n| **S_SC-P3-C032** | Trust funds require debtor-level records, continuous segregation, and statutorily restricted use. | S001 §111(B) | **High.** |\n| **S_SC-P3-C033** | Quarterly reporting of “charges deducted” does not, standing alone, establish authority to deduct every provider fee directly from the trust. | S001 §111 | **Hold/interpretive caution.** |\n| **S_SC-P3-C034** | Debtor payment must be deposited in trust no later than one business day after receipt. | S001 §111(B)(2) | **High.** |\n| **S_SC-P3-C035** | Creditor funds must be disbursed no later than five business days after receipt. | S001 §111(B)(3) | **High.** |\n| **S_SC-P3-C036** | Licensee must correct creditor payments misdirected due to its error. | S001 §111(B)(4) | **High.** |\n| **S_SC-P3-C037** | On request, consumer gets signed/dated receipts or electronic account-status access. | S001 §111(B)(5) | **High.** |\n| **S_SC-P3-C038** | Each trust account must be reconciled at least monthly against aggregate individual debtor escrow balances. | S001 §111(C) | **High.** No tolerance/cure period located. |\n| **S_SC-P3-C039** | Quarterly accounting must itemize receipts, creditor payments, agreed payoff figures, deductions and amount held. | S001 §111(D) | **High.** |\n| **S_SC-P3-C040** | Written-demand accounting is due within seven days, with no more than three required in each six-month period. | S001 §111(E) | **High text; exact calendar endpoint held.** |\n| **S_SC-P3-C041** | R.28-700 requires record of the FDIC-insured institution where SC consumer funds are held and account number. | S003 D(1)(d) | **High as recordkeeping text;** not overstated as standalone bank-eligibility clause. |\n| **S_SC-P3-C042** | Reviewed authorities do not establish blanket permission to delegate statutory custody to a third-party account administrator. | S001 §111; S003 | **Unresolved.** Agency/control and other-law analysis required. |\n| **S_SC-P3-C043** | Statute requires complete records and at least 3-year DMP retention; out-of-state records are subject to prompt DCA production requirements. | S001 §114 | **High.** |\n| **S_SC-P3-C044** | R.28-700 adds consumer/business record retention and permits equivalent accessible electronic records, subject to specific agency procedural requirements. | S003 D | **Qualified currentness as C027.** |\n| **S_SC-P3-C045** | Act111 became effective December2, 2005. | S002 | **High enactment history.** |\n| **S_SC-P3-C046** | Online statutory Code says current through 2026 Session. | S005 | **High as publisher status statement;** online not official print edition. |\n| **S_SC-P3-C047** | R.28-700 history shows 2006 adoption, 2009 amendment, 2016 amendment. | S003 history | **High historical status.** |\n| **S_SC-P3-C048** | P3 independently confirms no relevant Oct23 Register item, but does not freshly establish absence of every Apr–Sep2026 regulatory change. | S004, S012 | **Explicit currentness hold.** |\n| **S_SC-P3-C049** | 2010 DCA interpretations remain posted but DCA warns interpretations may later be superseded. | S009–S011 | **High status description; nonsupersession not certified.** |\n| **S_SC-P3-C050** | DCA checklist/FAQ are procedure/guidance rather than statutory permission. | S006–S007 | **High source-characterization limit.** |\n\n# D. Bounded agreement / money-flow / cancellation examples\n\nThese examples demonstrate only verified contractual or custody mechanics. They do **not** assume a provider is licensed or exempt, do not create a lawful fee, and do not resolve earlier fee holds.\n\n## Example 1 — Compensated negotiation, consumer retains all settlement money\n\n**Facts**\n\n- Provider negotiates reductions with three unsecured creditors.\n- Consumer pays creditors directly from the consumer's own bank account.\n- Provider never receives or controls the creditor-payment funds.\n- Assume only for this example that Chapter 7 applies and no exemption exists.\n\n**Result**\n\nThe negotiation itself can be covered under §101(3)(c). The general education/budget-analysis and written-contract requirements apply before compensated services. The §111 trust-account deposit/disbursement mechanics do not attach merely because negotiation occurs, because the $0 of creditor-distribution funds in this example are paid to the licensee.\n\nClient funds received for creditor distribution:\n\n$0\n\nTrust deposit required under §111 for those funds:\n\n$0\n\nThis does **not** mean the provider has no Chapter7 obligations. It means the §111 custody trigger is absent on these stated facts. If the provider gains withdrawal authority or control over the consumer's account, classification must be redone. **C001–C002, C005, C007, C029–C031.**\n\n## Example 2 — $600 received for creditor distribution\n\n**Facts**\n\n- A covered custodial DMP receives **$600** from the consumer exclusively for creditor distribution.\n- No provider fee is included in the $600.\n- Ignore actual calendar dates and use statutory business-day units.\n\n**Deposit**\n\nBase = $600 consumer creditor-payment money.\n\nRequired deposit:\n\n$600 × 100% = $600\n\nDeadline unit:\n\nno later than 1 business day after receipt\n\n**Creditor distribution**\n\nSuppose the agreed allocations are:\n\n- Creditor A: $250\n- Creditor B: $200\n- Creditor C: $150\n\nCheck:\n\n$250 + $200 + $150 = $600\n\nRequired total disbursement:\n\n$600\n\nDeadline:\n\nno later than 5 business days after receipt\n\nNo rounding issue exists because all amounts are whole cents/dollars as stated. **C029, C032, C034–C035.**\n\n## Example 3 — Cancellation after some creditor money has already been spent\n\n**Facts**\n\n- Consumer originally remitted $600 for creditors.\n- $350 was validly disbursed to creditors before cancellation becomes effective.\n- $250 remains unexpended.\n- No disputed provider fee is included in this calculation.\n\nCalculation:\n\nOriginal client funds: $600\n\nLess already disbursed creditor funds: −$350\n\nUnexpended balance:\n\n$600 − $350 = $250\n\n**Cancellation refund base = $250.**\n\nThe statute does not turn the earlier $350 creditor payments back into “unexpended funds.”\n\nIf someone contends that an additional $20 provider charge should be deducted from the $250:\n\n$250 − $20 = $230\n\nis **not** accepted in this example unless separate authority establishes that the $20 was lawful, earned, and properly deductible from these trust funds. Otherwise the correct status is:\n\n**$250 undisputed unexpended client-fund base; proposed $20 deduction held.**\n\nThis avoids double-deducting a fee previously paid elsewhere. **C025, C033.**\n\n## Example 4 — Monthly reconciliation\n\nAssume individual debtor trust ledgers show:\n\n- Debtor A: $120\n- Debtor B: $230\n- Debtor C: $150\n\nLedger total:\n\n$120 + $230 + $150 = $500\n\n### Case A — bank cash = $500\n\nDifference:\n\n$500 actual cash − $500 debtor-ledger total = $0\n\nReconciliation balances.\n\n### Case B — bank cash = $490\n\nDifference:\n\n$490 − $500 = −$10\n\nThere is a **$10 shortfall/discrepancy** requiring investigation/correction. The statute requires monthly reconciliation; PASS-03 did not locate a provision authorizing a tolerance or giving a specific cure period for a $10 discrepancy.\n\n**Result:** discrepancy identified; cure deadline **held**, not invented. **C038.**\n\n## Example 5 — Quarterly accounting arithmetic\n\nAssume during the quarter:\n\nFunds received: $900\n\nPaid Creditor A: $300\n\nPaid Creditor B: $250\n\nNo provider deductions are assumed.\n\nTotal creditor distributions:\n\n$300 + $250 = $550\n\nExpected amount held:\n\n$900 − $550 = $350\n\nThe quarterly accounting must separately report receipts, each creditor payment, agreed full-satisfaction figures where applicable, charges deducted, and trust balance.\n\nIf actual reported trust balance is $340 with no lawful $10 deduction or other transaction:\n\nExpected: $350\n\nActual: $340\n\nDifference:\n\n$340 − $350 = −$10\n\nThat is an unexplained $10 discrepancy, not a rounding adjustment. **C039.**\n\n## Example 6 — Ten-day cancellation: exact calendar date intentionally held\n\n**Facts**\n\nAssume the consumer gives a written cancellation notice on **October 24, 2026**.\n\nVerified law says:\n\n- cancellation may be requested at any time/any reason;\n- the mandatory clause specifies **10 days' written notice**;\n- §110(D) requires at least ten days' notice.\n\nWhat cannot safely be calculated from the reviewed provision alone is:\n\nOctober 24 + ? counting convention = exact effective cancellation date\n\nbecause this pass did not verify an applicable Chapter7/private-contract rule establishing whether the trigger is sending or receipt, whether day zero counts, or the treatment of weekends/holidays.\n\n**Result: exact endpoint HELD.**\n\nIf $425 remains unexpended when cancellation legally becomes effective, refund base:\n\n$425 × 100% = $425\n\nBut the statute reviewed does not provide an independent “refund must be paid within X days thereafter” deadline, so the payout date is also **held**. **C020–C025, C028.**\n\n## Example 7 — Conditional §109 setup refund without importing an old fee amount\n\nLet **X** equal the amount of a setup fee that was independently lawful under the applicable fee rules.\n\nAssume all §109(A) conditions occur:\n\n- a DMP was established;\n- within the statutory 45-day condition, creditor failure to consent makes the DMP unsuitable.\n\nRefund operator:\n\nX × 100% = X\n\nResult:\n\n**the setup fee X must be returned and the account closed.**\n\nThis example intentionally does not supply a dollar amount, because PASS-03 is not reopening fee ceilings. It also does not assign an exact calendar “day 45” endpoint without an established counting rule. **C026.**\n\n## Example 8 — Third-party “special purpose account”\n\n**Facts**\n\nConsumer deposits $2,000 in an account titled in the consumer's name. A separate account company appears in the documentation. The settlement provider can initiate or direct payments.\n\nThe visible title alone does not determine the legal result.\n\nQuestions required before classifying the money flow:\n\n1. Can the consumer withdraw without provider permission?\n2. Can the provider originate transfers?\n3. Can the provider block transfers?\n4. Is the account company the provider's agent?\n5. Who has contractual control?\n6. Is any money legally paid “to the licensee for disbursement”?\n\nUntil those facts are established:\n\n$2,000 × unknown custody classification = HOLD\n\nIt is improper to call this automatically “noncustodial” merely because a third party holds the bank account. **C031, C042.**\n\n# E. PASS-03 component coverage and remaining gaps\n\n| Question / component | Status | Claim IDs | Exact missing authority / next action |\n| --- | --- | --- | --- |\n| General written agreement requirement for compensated covered services | **Answered** | C005, C007–C009 | Entity-specific coverage/exemption remains factual. |\n| Negotiation-only vs custodial DMP contract distinction | **Answered materially** | C001–C002, C010–C011 | Mixed/control models require agreement/account facts. |\n| Budget-analysis and pre-service documents | **Answered** | C005–C006 | Automated/unlicensed intake edge may need later authority for specific system design. |\n| Mandatory contract contents | **Answered** | C009–C010, C015–C016 | Earlier fee-permission questions remain separate. |\n| Creditor participation/consent records | **Answered** | C010, C012–C013 | FAQ paper requirement remains agency guidance rather than statute. |\n| Executed contract copy delivery to consumer | **Partial / unresolved** | C014 | Check generally applicable SC consumer-contract law and any later DCA interpretation expressly requiring executed-copy delivery. |\n| Language/readability | **Answered for specific statutory formatting; partial generally** | C015 | No general font/grade-level rule found; broader general-law requirements not investigated. |\n| Electronic signatures | **Answered under SC UETA** | C017 | Provider implementation still requires actual party-consent evidence. |\n| Electronic delivery/retention | **Answered under SC UETA, federal overlay partial** | C018–C019 | Current federal E-SIGN §101(c) implementation must be independently checked before deploying electronic-only consumer disclosures. |\n| Cancellation right | **Answered** | C020–C023 | Method-specific implementation may depend on UETA/contract. |\n| Exact 10-day calendar computation | **Unresolved** | C024 | Locate controlling SC authority applying a counting rule to §37-7-110 private notice; then apply actual transmission/receipt facts. |\n| Cooling-off period | **Answered: no initial-only cooling-off rule located; continuous termination instead** | C022 | Broader generally applicable rescission regimes outside Chapter7 not investigated. |\n| Cancellation refund measure | **Answered** | C025 | Disputed earned fees need fee-specific authority/facts. |\n| Cancellation refund payment deadline | **Unresolved** | C028 | Locate statute/regulation/formal interpretation/case prescribing payment timing, if any. |\n| §109 conditional setup refund | **Answered at structural level only** | C026 | Prior fee/currentness/sequencing holds remain. |\n| Trust-account trigger | **Answered** | C029–C031 | Actual third-party/control structures remain factual/legal dependency. |\n| Segregation and permissible use | **Answered, with fee-deduction hold** | C032–C033 | Need authoritative interpretation whether/when provider compensation may be withdrawn directly from statutory trust. |\n| One-business-day deposit | **Answered** | C034 | Exact calendar date requires receipt timestamp and applicable holiday/business-day facts. |\n| Five-business-day creditor distribution | **Answered** | C035 | Same factual calendar dependency. |\n| Misdirected payments | **Answered** | C036 | Full loss/remedy architecture deferred. |\n| Consumer receipts/electronic account access | **Answered** | C037 | Technical standard for electronic access not specified in provision. |\n| Monthly reconciliation | **Answered** | C038 | Cure deadline/tolerance for discrepancies not found. |\n| Quarterly accounting | **Answered** | C039 | Precise treatment of disputed deductions remains held. |\n| Demand accounting within seven days | **Answered textually** | C040 | Exact calendar endpoint requires counting rule/receipt facts. |\n| FDIC-insured institution requirement | **Partial/qualified** | C041 | Regulation phrases this as required record about institution; locate any separate affirmative depository-account rule if stronger proposition is needed. |\n| Third-party account administrator authority | **Unresolved** | C042 | Need contract/control facts plus any DCA interpretation/order and potentially separate money-transmission/banking law. |\n| Statutory record retention | **Answered** | C043 | Enforcement/exam architecture deferred. |\n| Regulatory record retention/electronic records | **Answered subject to currentness hold** | C044, C048 | Freshly check intervening Apr–Sep2026 Register issues before formal current-law reliance on regulation. |\n| Statutory enactment/currentness | **Answered** | C045–C046 | Official printed-code caveat preserved. |\n| Regulation currentness through Oct24 2026 | **Partial** | C047–C048 | Apr–Sep 2026 State Register issues not freshly re-read in this pass. |\n| 2010 interpretations present status | **Partial** | C049 | DCA itself warns to confirm supersession before formal reliance. |\n| Provider authorization | **Excluded / not established** | — | Requires actual current license/status evidence in separate component. |\n| Complete fee architecture | **Excluded from PASS-03** | — | PASS-01/PASS-02 holds remain; not reopened. |\n| Bonds/insurance | **Excluded except where custody concept intersects** | — | Separate required pass. |\n| Complaint/exam/enforcement/private remedies | **Excluded except contract voidness/direct return rights** | C016 | Separate pass required. |\n| Full collection/litigation/limitations/debtor exemptions/secured debt/sector/local/tribal/case law | **Open / excluded** | — | Separate parent investigations required. |\n| State/A066 acceptance | **Not performed** | — | No implication of completion. |\n\n# F. Researcher self-check\n\nThis is a **researcher self-check, not independent review**.\n\n### Actually read in this pass\n\nI freshly read the operative Chapter 7 provisions dealing with definitions/nexus, education and budget analysis, creditor consent, contracts, cancellation, trust funds, records, and prohibited contract practices. I also read the relevant R.28-700 recordkeeping/fee-contract passages and inspected the corresponding PDF pages rather than relying on search snippets. [South Carolina Legislature+5](https://www.scstatehouse.gov/code/t37c007.php)\n\nI freshly read South Carolina's UETA provisions relevant to electronic signatures, electronic records, retention, and party consent. [South Carolina Legislature](https://www.scstatehouse.gov/code/t26c006.php)\n\nI freshly inspected the page images of DCA Administrative Interpretations **7.108-1001 and 7.108-1003** for the limited issues used here, rather than assuming PASS-02's treatment was coordinator-approved. [Consumer Affairs+3](https://www.consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf)\n\nI read the DCA counseling checklist and FAQ for agency procedural treatment and kept those materials subordinate to statute/regulation. [Consumer Affairs+1](https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Regulatory/Credit%20Counseling/Forms/Foreclosure%20Counseling%20Guidance.pdf)\n\nI checked the statute's current-publication statement, regulation compilation cutoff, enactment history, and the actual October23, 2026 State Register issue. [South Carolina Legislature+3](https://www.scstatehouse.gov/code/statmast.php)\n\n### Explicitly not established\n\nI did **not**:\n\n- establish SettleADebt.com or any other provider's authorization;\n- rerun or validate the full PASS-01 fee analysis;\n- deem PASS-02 coordinator-reviewed or adopt all of its conclusions;\n- resolve the prior §109 setup-fee/contract sequencing hold;\n- establish an exact private-law counting convention for the ten-day cancellation period or seven-day accounting period;\n- establish a statutory refund-payout deadline where the reviewed text supplies none;\n- establish blanket authority for third-party custody or special-purpose account administrators;\n- establish that every provider fee may be deducted from the statutory trust account;\n- freshly review every April–September 2026 State Register issue;\n- conduct a complete federal E-SIGN analysis;\n- conduct the broader bonds, insurance, examination, remedies, collection, limitations, secured-debt, local, tribal, sector, or comprehensive case-law passes;\n- make a local write, file, publication, filing, contact, account change, or website change;\n- claim independent review, publication readiness, full South Carolina acceptance, or A066 acceptance.\n\n**END S_SC PASS-03**\n\n","tables":[{"headers":["Source ID","Issuer / title","Direct source","Exact passage/read","Legal/status characterization and limitations"],"index":0,"links":[{"href":"https://www.scstatehouse.gov/code/t37c007.php?utm_source=chatgpt.com","text":"Direct Chapter 7 text"},{"href":"https://www.scstatehouse.gov/sess116_2005-2006/bills/607.htm?utm_source=chatgpt.com","text":"Direct enrolled-act/history page"},{"href":"https://www.scstatehouse.gov/coderegs/Chapter%2028.pdf?utm_source=chatgpt.com","text":"Direct Chapter 28 PDF"},{"href":"https://www.scstatehouse.gov/coderegs/statmast.php?utm_source=chatgpt.com","text":"Regulation compilation status"},{"href":"https://www.scstatehouse.gov/code/statmast.php?utm_source=chatgpt.com","text":"Code status/disclaimer"},{"href":"https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Regulatory/Credit%20Counseling/Forms/Foreclosure%20Counseling%20Guidance.pdf?utm_source=chatgpt.com","text":"Direct DCA checklist PDF"},{"href":"https://consumer.sc.gov/consumer-faqs/credit-counseling-faqs?utm_source=chatgpt.com","text":"DCA Credit Counseling FAQ"},{"href":"https://www.scstatehouse.gov/code/t26c006.php?utm_source=chatgpt.com","text":"Direct South Carolina UETA text"},{"href":"https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf?utm_source=chatgpt.com","text":"Direct interpretation PDF"},{"href":"https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1001%20Credit%20Counselor%20-%20Budget%20Analysis.pdf?utm_source=chatgpt.com","text":"Direct interpretation PDF"},{"href":"https://consumer.sc.gov/business-resourceslaws/administrative-interpretations/chapter-seven?utm_source=chatgpt.com","text":"DCA Chapter Seven interpretation index"},{"href":"https://www.scstatehouse.gov/state_register.php?file=Sr50-10.pdf&first=FILE&pdf=1&utm_source=chatgpt.com","text":"Direct October 23, 2026 issue PDF"},{"href":"https://www.sccourts.org/media/opinions/HTMLFiles/SC/26648.htm?utm_source=chatgpt.com","text":"Official court opinion page"}],"row_links":[[],[{"href":"https://www.scstatehouse.gov/code/t37c007.php?utm_source=chatgpt.com","text":"Direct Chapter 7 text"}],[{"href":"https://www.scstatehouse.gov/sess116_2005-2006/bills/607.htm?utm_source=chatgpt.com","text":"Direct enrolled-act/history page"}],[{"href":"https://www.scstatehouse.gov/coderegs/Chapter%2028.pdf?utm_source=chatgpt.com","text":"Direct Chapter 28 PDF"}],[{"href":"https://www.scstatehouse.gov/coderegs/statmast.php?utm_source=chatgpt.com","text":"Regulation compilation status"}],[{"href":"https://www.scstatehouse.gov/code/statmast.php?utm_source=chatgpt.com","text":"Code status/disclaimer"}],[{"href":"https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Regulatory/Credit%20Counseling/Forms/Foreclosure%20Counseling%20Guidance.pdf?utm_source=chatgpt.com","text":"Direct DCA checklist PDF"}],[{"href":"https://consumer.sc.gov/consumer-faqs/credit-counseling-faqs?utm_source=chatgpt.com","text":"DCA Credit Counseling FAQ"}],[{"href":"https://www.scstatehouse.gov/code/t26c006.php?utm_source=chatgpt.com","text":"Direct South Carolina UETA text"}],[{"href":"https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf?utm_source=chatgpt.com","text":"Direct interpretation PDF"}],[{"href":"https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1001%20Credit%20Counselor%20-%20Budget%20Analysis.pdf?utm_source=chatgpt.com","text":"Direct interpretation PDF"}],[{"href":"https://consumer.sc.gov/business-resourceslaws/administrative-interpretations/chapter-seven?utm_source=chatgpt.com","text":"DCA Chapter Seven interpretation index"}],[{"href":"https://www.scstatehouse.gov/state_register.php?file=Sr50-10.pdf&first=FILE&pdf=1&utm_source=chatgpt.com","text":"Direct October 23, 2026 issue PDF"}],[{"href":"https://www.sccourts.org/media/opinions/HTMLFiles/SC/26648.htm?utm_source=chatgpt.com","text":"Official court opinion page"}]],"rows":[["Source ID","Issuer / title","Direct source","Exact passage/read","Legal/status characterization and limitations"],["S_SC-P3-S001","South Carolina General Assembly — Title 37, Chapter 7, Consumer Credit Counseling","Direct Chapter 7 text","§§37-7-101, 102, 108–111, 114, 116; especially statutory lines reflected in turn574189view0, turn186003view0, turn253842view0, turn685233view1.","Current statutory compilation through 2026 Session per S005; online compilation not official printed Code. Freshly read."],["S_SC-P3-S002","South Carolina General Assembly — Act 111 of 2005 / S.607","Direct enrolled-act/history page","Status and enactment history; became law without signature June 2, 2005; effective December 2, 2005.","Enacted historical foundation, not merely bill text. Freshly checked."],["S_SC-P3-S003","South Carolina Code of Regulations — Chapter 28, R.28-700","Direct Chapter 28 PDF","R.28-700(B), (D), history; PDF pp.35–38. Page images actually inspected as turn257930view0–turn257930view2.","Operative text in online compilation; history last amendment Feb.26, 2016. Compilation-currentness limitation in S004."],["S_SC-P3-S004","South Carolina General Assembly — Code of Regulations status","Regulation compilation status","Statement that compilation is current through State Register Vol.50 Issue3, March27, 2026; online disclaimer.","Currentness boundary; intervening Apr–Sep issues not freshly re-reviewed in this pass."],["S_SC-P3-S005","South Carolina General Assembly — Code of Laws status","Code status/disclaimer","Current through 2026 Session and online/official-print disclaimer.","Supports statutory currentness, subject to site's stated limitation."],["S_SC-P3-S006","South Carolina DCA — Foreclosure/Housing Counseling Compliance Guidance","Direct DCA checklist PDF","Contract checklist and separate “if receiving consumer money for disbursement” requirements; page image inspected as turn746933view0.","Agency guidance, expressly not a substitute for law. Useful for DCA's general-vs-custodial contract distinction."],["S_SC-P3-S007","South Carolina DCA — Credit Counseling FAQs","DCA Credit Counseling FAQ","Creditor-consent form and paper-file instruction.","Agency procedural guidance; no separate legal effective date located."],["S_SC-P3-S008","South Carolina General Assembly — Uniform Electronic Transactions Act, Title 26 Ch.6","Direct South Carolina UETA text","§§26-6-30, 50, 70, 80: party agreement, e-record/e-signature effect, retainability, formatting, E-SIGN preservation.","Current state statute; used only for electronic-form questions."],["S_SC-P3-S009","South Carolina DCA — Administrative Interpretation 7.108-1003","Direct interpretation PDF","All 3 pages freshly inspected as page images turn780132view0–turn780132view2; prerequisite/assignment/compensation analysis.","Issued June29, 2010. Agency administrative interpretation, not regulation/court holding. Current index has supersession warning."],["S_SC-P3-S010","South Carolina DCA — Administrative Interpretation 7.108-1001","Direct interpretation PDF","Both pages freshly inspected as images turn780132view3–turn780132view4.","Issued April15, 2010. Same status limitation as S009."],["S_SC-P3-S011","South Carolina DCA — Chapter Seven Administrative Interpretations index","DCA Chapter Seven interpretation index","Current listing of 1001/1003 and warning regarding subsequent changes/supersession.","Current administrative index; listing ≠ formal nonsupersession determination."],["S_SC-P3-S012","South Carolina State Register Vol.50 Issue10","Direct October 23, 2026 issue PDF","Publication metadata, contents, targeted searches for DCA/R.28-700/credit counseling; TOC page image inspected.","Published Oct.23, 2026. No relevant amendment found. Does not fill Apr–Sep PASS-03 gap."],["S_SC-P3-S013","South Carolina Supreme Court — Lexington Law Firm v. SCDCA, Op.26648","Official court opinion page","Used only as a bounded exemption cross-check: attorney category requires actual statutory conditions, not attorney branding alone.","Filed May12, 2009; controlling judicial authority on the exemption issue. No broader case-law pass performed."]]},{"headers":["Claim ID","Consequential assertion","Source / pinpoint","Conditions, exceptions, currentness, confidence"],"index":1,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Claim ID","Consequential assertion","Source / pinpoint","Conditions, exceptions, currentness, confidence"],["S_SC-P3-C001","Negotiating deferral/reduction of third-party credit obligations is independently covered conduct; receipt of client funds is not required for that category.","S001 §37-7-101(3)(c)","High statutory text. Compensation/entity/exemption conditions still apply."],["S_SC-P3-C002","A DMP additionally involves settlement/pooling/distribution plus consumer money or control of funds for creditor distribution.","S001 §101(6)–(7)","High. Actual control matters more than product label."],["S_SC-P3-C003","Soliciting or contracting with SC debtors can establish nexus without physical SC presence.","S001 §§101(2)(a), 102","High. Provider-specific facts not established."],["S_SC-P3-C004","Chapter 7 exclusions are conditioned, including attorney and nonprofit-faith-based categories; labels alone do not establish exemption.","S001 §101(2)(b); S013","High for statutory conditions; no entity-specific exemption determination."],["S_SC-P3-C005","Before covered counseling/DMP activity, §108 requires education, written budget analysis delivered to debtor, suitability finding, and separate retainable warning document.","S001 §108","High."],["S_SC-P3-C006","DCA 7.108-1001 interprets statutory budget-analysis collection as requiring a licensed counselor in the circumstances addressed.","S010 pp.1–2","High as agency interpretation, not court holding/regulation."],["S_SC-P3-C007","Compensated services generally require a written, dated consumer-signed contract before provision; §110(A) contains an express §109(A) setup-fee exception.","S001 §110(A)","High text. Exact setup-fee sequencing remains held from earlier work."],["S_SC-P3-C008","DCA 7.108-1003 interprets education, budget analysis, and compliant written contract as pre-service requirements for compensated counseling; assignment has conditional treatment.","S009 pp.2–3","High as agency interpretation. No PASS-02 verification status assumed."],["S_SC-P3-C009","Contract must identify parties, estimate all consumer payments/fees including maximum, describe services/guarantees, and state performance period ≤5 years.","S001 §110(B)(1),(2),(4)","High. Does not validate any fee amount."],["S_SC-P3-C010","Custodial DMP contract provisions include consumer-to-provider creditor-payment schedule, creditor participation details and nonparticipant list.","S001 §110(B)(3),(5),(6)","High text for DMP context."],["S_SC-P3-C011","DCA operational guidance distinguishes general contract requirements from additional provisions when receiving consumer money for creditor disbursement.","S006 contract checklist","Moderate/high as agency procedural interpretation; not independent legal authority."],["S_SC-P3-C012","DMP creditor-consent record must document creditor list, solicitation method/date, responses/conditions, and consent timing.","S001 §109(B)–(D)","High."],["S_SC-P3-C013","DCA FAQ currently instructs that creditor-consent form be placed on paper in client's paper file even where source data is electronic.","S007","Agency-procedure claim only. No statutory-paper-only rule inferred beyond that guidance."],["S_SC-P3-C014","§108 expressly requires delivery/retainability of the budget analysis/disclosure; no express executed-contract-copy delivery clause was found in reviewed Chapter7/R.28-700 text.","S001 §§108,110; S003 D(1)(a)","Qualified negative finding. General law or later authority may add obligations."],["S_SC-P3-C015","Specific presentation controls include clear/conspicuous standalone §108 disclosure, bold conspicuous cancellation language near signature, and fully completed agreement before signature.","S001 §§108,110,116","High. No general readability metric located."],["S_SC-P3-C016","Waivers, DMP rescission fee, specified ancillary conditions, unfair/deceptive terms, and collection before earned are prohibited; §116 violation renders agreement void.","S001 §116","High. Broader remedy architecture excluded."],["S_SC-P3-C017","SC UETA recognizes electronic records/signatures where parties agree to transact electronically.","S008 §§26-6-50,70","High state-law rule. Other law can impose additional requirements."],["S_SC-P3-C018","Required written information can be electronic only where recipient can retain it; sender cannot inhibit printing/storage and substantive formatting requirements survive.","S008 §26-6-80","High."],["S_SC-P3-C019","SC UETA preserves federal E-SIGN §101(c); exact federal consumer-consent implementation is not fully reverified in this pass.","S008 §26-6-30","State-law preservation high; federal implementation held."],["S_SC-P3-C020","Mandatory contract language grants cancellation any time/any reason without penalty through 10 days' written notice, followed by refund of unexpended funds.","S001 §110(B)(7)","High. Exact calendar endpoint not established."],["S_SC-P3-C021","§110(D) independently requires DMP cancellation on consumer request with at least ten days' notice and refund of all unexpended funds.","S001 §110(D)","High."],["S_SC-P3-C022","This is a continuing termination right rather than a limited initial cooling-off window.","S001 §110(B)(7),(D)","High textual characterization."],["S_SC-P3-C023","Statute does not enumerate a specific cancellation transmission channel; electronic notice may qualify as writing only subject to applicable UETA/contract requirements.","S001 §110; S008","Qualified."],["S_SC-P3-C024","No Chapter7 counting rule establishing an exact calendar cancellation endpoint was located; litigation Rule6 is not imported without authority.","S001 §110; targeted counting-rule review","Hold."],["S_SC-P3-C025","Cancellation refund is all unexpended funds, not automatically every historic payment or amount already remitted to creditors.","S001 §110(B)(7),(D)","High for measure; earned-fee disputes remain separate."],["S_SC-P3-C026","§109(A)'s suitability failure can separately require return of the setup fee/account closure.","S001 §109(A)","High condition; exact fee mechanics not revisited."],["S_SC-P3-C027","R.28-700 separately requires return of money received in violation of Act/regulation.","S003 B(4)","Qualified currentness because Apr–Sep 2026 Register not freshly rechecked in P3."],["S_SC-P3-C028","No separate X-day deadline for paying the §110 unexpended-funds cancellation refund was located.","S001 §110","Hold on payment timing."],["S_SC-P3-C029","Funds paid to licensee for creditor disbursement must enter a trust account established for debtors' benefit.","S001 §111(B)","High."],["S_SC-P3-C030","Consumer-retained funds in a genuinely noncustodial negotiation model are not, solely by virtue of the negotiation, funds “paid to the licensee for disbursement.”","S001 §§101,111","High textual distinction; actual account/control facts govern."],["S_SC-P3-C031","Control of funds can satisfy the DMP definition even without literal possession.","S001 §101(6)","High. Third-party account arrangements require factual review."],["S_SC-P3-C032","Trust funds require debtor-level records, continuous segregation, and statutorily restricted use.","S001 §111(B)","High."],["S_SC-P3-C033","Quarterly reporting of “charges deducted” does not, standing alone, establish authority to deduct every provider fee directly from the trust.","S001 §111","Hold/interpretive caution."],["S_SC-P3-C034","Debtor payment must be deposited in trust no later than one business day after receipt.","S001 §111(B)(2)","High."],["S_SC-P3-C035","Creditor funds must be disbursed no later than five business days after receipt.","S001 §111(B)(3)","High."],["S_SC-P3-C036","Licensee must correct creditor payments misdirected due to its error.","S001 §111(B)(4)","High."],["S_SC-P3-C037","On request, consumer gets signed/dated receipts or electronic account-status access.","S001 §111(B)(5)","High."],["S_SC-P3-C038","Each trust account must be reconciled at least monthly against aggregate individual debtor escrow balances.","S001 §111(C)","High. No tolerance/cure period located."],["S_SC-P3-C039","Quarterly accounting must itemize receipts, creditor payments, agreed payoff figures, deductions and amount held.","S001 §111(D)","High."],["S_SC-P3-C040","Written-demand accounting is due within seven days, with no more than three required in each six-month period.","S001 §111(E)","High text; exact calendar endpoint held."],["S_SC-P3-C041","R.28-700 requires record of the FDIC-insured institution where SC consumer funds are held and account number.","S003 D(1)(d)","High as recordkeeping text; not overstated as standalone bank-eligibility clause."],["S_SC-P3-C042","Reviewed authorities do not establish blanket permission to delegate statutory custody to a third-party account administrator.","S001 §111; S003","Unresolved. Agency/control and other-law analysis required."],["S_SC-P3-C043","Statute requires complete records and at least 3-year DMP retention; out-of-state records are subject to prompt DCA production requirements.","S001 §114","High."],["S_SC-P3-C044","R.28-700 adds consumer/business record retention and permits equivalent accessible electronic records, subject to specific agency procedural requirements.","S003 D","Qualified currentness as C027."],["S_SC-P3-C045","Act111 became effective December2, 2005.","S002","High enactment history."],["S_SC-P3-C046","Online statutory Code says current through 2026 Session.","S005","High as publisher status statement; online not official print edition."],["S_SC-P3-C047","R.28-700 history shows 2006 adoption, 2009 amendment, 2016 amendment.","S003 history","High historical status."],["S_SC-P3-C048","P3 independently confirms no relevant Oct23 Register item, but does not freshly establish absence of every Apr–Sep2026 regulatory change.","S004, S012","Explicit currentness hold."],["S_SC-P3-C049","2010 DCA interpretations remain posted but DCA warns interpretations may later be superseded.","S009–S011","High status description; nonsupersession not certified."],["S_SC-P3-C050","DCA checklist/FAQ are procedure/guidance rather than statutory permission.","S006–S007","High source-characterization limit."]]},{"headers":["Question / component","Status","Claim IDs","Exact missing authority / next action"],"index":2,"links":[],"row_links":[[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[],[]],"rows":[["Question / component","Status","Claim IDs","Exact missing authority / next action"],["General written agreement requirement for compensated covered services","Answered","C005, C007–C009","Entity-specific coverage/exemption remains factual."],["Negotiation-only vs custodial DMP contract distinction","Answered materially","C001–C002, C010–C011","Mixed/control models require agreement/account facts."],["Budget-analysis and pre-service documents","Answered","C005–C006","Automated/unlicensed intake edge may need later authority for specific system design."],["Mandatory contract contents","Answered","C009–C010, C015–C016","Earlier fee-permission questions remain separate."],["Creditor participation/consent records","Answered","C010, C012–C013","FAQ paper requirement remains agency guidance rather than statute."],["Executed contract copy delivery to consumer","Partial / unresolved","C014","Check generally applicable SC consumer-contract law and any later DCA interpretation expressly requiring executed-copy delivery."],["Language/readability","Answered for specific statutory formatting; partial generally","C015","No general font/grade-level rule found; broader general-law requirements not investigated."],["Electronic signatures","Answered under SC UETA","C017","Provider implementation still requires actual party-consent evidence."],["Electronic delivery/retention","Answered under SC UETA, federal overlay partial","C018–C019","Current federal E-SIGN §101(c) implementation must be independently checked before deploying electronic-only consumer disclosures."],["Cancellation right","Answered","C020–C023","Method-specific implementation may depend on UETA/contract."],["Exact 10-day calendar computation","Unresolved","C024","Locate controlling SC authority applying a counting rule to §37-7-110 private notice; then apply actual transmission/receipt facts."],["Cooling-off period","Answered: no initial-only cooling-off rule located; continuous termination instead","C022","Broader generally applicable rescission regimes outside Chapter7 not investigated."],["Cancellation refund measure","Answered","C025","Disputed earned fees need fee-specific authority/facts."],["Cancellation refund payment deadline","Unresolved","C028","Locate statute/regulation/formal interpretation/case prescribing payment timing, if any."],["§109 conditional setup refund","Answered at structural level only","C026","Prior fee/currentness/sequencing holds remain."],["Trust-account trigger","Answered","C029–C031","Actual third-party/control structures remain factual/legal dependency."],["Segregation and permissible use","Answered, with fee-deduction hold","C032–C033","Need authoritative interpretation whether/when provider compensation may be withdrawn directly from statutory trust."],["One-business-day deposit","Answered","C034","Exact calendar date requires receipt timestamp and applicable holiday/business-day facts."],["Five-business-day creditor distribution","Answered","C035","Same factual calendar dependency."],["Misdirected payments","Answered","C036","Full loss/remedy architecture deferred."],["Consumer receipts/electronic account access","Answered","C037","Technical standard for electronic access not specified in provision."],["Monthly reconciliation","Answered","C038","Cure deadline/tolerance for discrepancies not found."],["Quarterly accounting","Answered","C039","Precise treatment of disputed deductions remains held."],["Demand accounting within seven days","Answered textually","C040","Exact calendar endpoint requires counting rule/receipt facts."],["FDIC-insured institution requirement","Partial/qualified","C041","Regulation phrases this as required record about institution; locate any separate affirmative depository-account rule if stronger proposition is needed."],["Third-party account administrator authority","Unresolved","C042","Need contract/control facts plus any DCA interpretation/order and potentially separate money-transmission/banking law."],["Statutory record retention","Answered","C043","Enforcement/exam architecture deferred."],["Regulatory record retention/electronic records","Answered subject to currentness hold","C044, C048","Freshly check intervening Apr–Sep2026 Register issues before formal current-law reliance on regulation."],["Statutory enactment/currentness","Answered","C045–C046","Official printed-code caveat preserved."],["Regulation currentness through Oct24 2026","Partial","C047–C048","Apr–Sep 2026 State Register issues not freshly re-read in this pass."],["2010 interpretations present status","Partial","C049","DCA itself warns to confirm supersession before formal reliance."],["Provider authorization","Excluded / not established","—","Requires actual current license/status evidence in separate component."],["Complete fee architecture","Excluded from PASS-03","—","PASS-01/PASS-02 holds remain; not reopened."],["Bonds/insurance","Excluded except where custody concept intersects","—","Separate required pass."],["Complaint/exam/enforcement/private remedies","Excluded except contract voidness/direct return rights","C016","Separate pass required."],["Full collection/litigation/limitations/debtor exemptions/secured debt/sector/local/tribal/case law","Open / excluded","—","Separate parent investigations required."],["State/A066 acceptance","Not performed","—","No implication of completion."]]}],"claims":[{"claim_id":"S_SC-P3-C001","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P3-C001","Consequential assertion":"Negotiating deferral/reduction of third-party credit obligations is independently covered conduct; receipt of client funds is not required for that category.","Source / pinpoint":"S001 §37-7-101(3)(c)","Conditions, exceptions, currentness, confidence":"High statutory text. Compensation/entity/exemption conditions still apply."},"coordinator_verification_status":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_SC-P3-C002","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P3-C002","Consequential assertion":"A DMP additionally involves settlement/pooling/distribution plus consumer money or control of funds for creditor distribution.","Source / pinpoint":"S001 §101(6)–(7)","Conditions, exceptions, currentness, confidence":"High. Actual control matters more than product label."},"coordinator_verification_status":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_SC-P3-C003","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P3-C003","Consequential assertion":"Soliciting or contracting with SC debtors can establish nexus without physical SC presence.","Source / pinpoint":"S001 §§101(2)(a), 102","Conditions, exceptions, currentness, confidence":"High. Provider-specific facts not established."},"coordinator_verification_status":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_SC-P3-C004","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P3-C004","Consequential assertion":"Chapter 7 exclusions are conditioned, including attorney and nonprofit-faith-based categories; labels alone do not establish exemption.","Source / pinpoint":"S001 §101(2)(b); S013","Conditions, exceptions, currentness, confidence":"High for statutory conditions; no entity-specific exemption determination."},"coordinator_verification_status":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_SC-P3-C005","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P3-C005","Consequential assertion":"Before covered counseling/DMP activity, §108 requires education, written budget analysis delivered to debtor, suitability finding, and separate retainable warning document.","Source / pinpoint":"S001 §108","Conditions, exceptions, currentness, confidence":"High."},"coordinator_verification_status":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_SC-P3-C006","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P3-C006","Consequential assertion":"DCA 7.108-1001 interprets statutory budget-analysis collection as requiring a licensed counselor in the circumstances addressed.","Source / pinpoint":"S010 pp.1–2","Conditions, exceptions, currentness, confidence":"High as agency interpretation, not court holding/regulation."},"coordinator_verification_status":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_SC-P3-C007","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P3-C007","Consequential assertion":"Compensated services generally require a written, dated consumer-signed contract before provision; §110(A) contains an express §109(A) setup-fee exception.","Source / pinpoint":"S001 §110(A)","Conditions, exceptions, currentness, confidence":"High text. Exact setup-fee sequencing remains held from earlier work."},"coordinator_verification_status":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_SC-P3-C008","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P3-C008","Consequential assertion":"DCA 7.108-1003 interprets education, budget analysis, and compliant written contract as pre-service requirements for compensated counseling; assignment has conditional treatment.","Source / pinpoint":"S009 pp.2–3","Conditions, exceptions, currentness, confidence":"High as agency interpretation. No PASS-02 verification status assumed."},"coordinator_verification_status":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_SC-P3-C009","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P3-C009","Consequential assertion":"Contract must identify parties, estimate all consumer payments/fees including maximum, describe services/guarantees, and state performance period ≤5 years.","Source / pinpoint":"S001 §110(B)(1),(2),(4)","Conditions, exceptions, currentness, confidence":"High. Does not validate any fee amount."},"coordinator_verification_status":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_SC-P3-C010","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P3-C010","Consequential assertion":"Custodial DMP contract provisions include consumer-to-provider creditor-payment schedule, creditor participation details and nonparticipant list.","Source / pinpoint":"S001 §110(B)(3),(5),(6)","Conditions, exceptions, currentness, confidence":"High text for DMP context."},"coordinator_verification_status":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_SC-P3-C011","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P3-C011","Consequential assertion":"DCA operational guidance distinguishes general contract requirements from additional provisions when receiving consumer money for creditor disbursement.","Source / pinpoint":"S006 contract checklist","Conditions, exceptions, currentness, confidence":"Moderate/high as agency procedural interpretation; not independent legal authority."},"coordinator_verification_status":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_SC-P3-C012","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P3-C012","Consequential assertion":"DMP creditor-consent record must document creditor list, solicitation method/date, responses/conditions, and consent timing.","Source / pinpoint":"S001 §109(B)–(D)","Conditions, exceptions, currentness, confidence":"High."},"coordinator_verification_status":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_SC-P3-C013","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P3-C013","Consequential assertion":"DCA FAQ currently instructs that creditor-consent form be placed on paper in client's paper file even where source data is electronic.","Source / pinpoint":"S007","Conditions, exceptions, currentness, confidence":"Agency-procedure claim only. No statutory-paper-only rule inferred beyond that guidance."},"coordinator_verification_status":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_SC-P3-C014","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P3-C014","Consequential assertion":"§108 expressly requires delivery/retainability of the budget analysis/disclosure; no express executed-contract-copy delivery clause was found in reviewed Chapter7/R.28-700 text.","Source / pinpoint":"S001 §§108,110; S003 D(1)(a)","Conditions, exceptions, currentness, confidence":"Qualified negative finding. General law or later authority may add obligations."},"coordinator_verification_status":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_SC-P3-C015","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P3-C015","Consequential assertion":"Specific presentation controls include clear/conspicuous standalone §108 disclosure, bold conspicuous cancellation language near signature, and fully completed agreement before signature.","Source / pinpoint":"S001 §§108,110,116","Conditions, exceptions, currentness, confidence":"High. No general readability metric located."},"coordinator_verification_status":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_SC-P3-C016","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P3-C016","Consequential assertion":"Waivers, DMP rescission fee, specified ancillary conditions, unfair/deceptive terms, and collection before earned are prohibited; §116 violation renders agreement void.","Source / pinpoint":"S001 §116","Conditions, exceptions, currentness, confidence":"High. Broader remedy architecture excluded."},"coordinator_verification_status":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_SC-P3-C017","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P3-C017","Consequential assertion":"SC UETA recognizes electronic records/signatures where parties agree to transact electronically.","Source / pinpoint":"S008 §§26-6-50,70","Conditions, exceptions, currentness, confidence":"High state-law rule. Other law can impose additional requirements."},"coordinator_verification_status":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_SC-P3-C018","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P3-C018","Consequential assertion":"Required written information can be electronic only where recipient can retain it; sender cannot inhibit printing/storage and substantive formatting requirements survive.","Source / pinpoint":"S008 §26-6-80","Conditions, exceptions, currentness, confidence":"High."},"coordinator_verification_status":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_SC-P3-C019","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P3-C019","Consequential assertion":"SC UETA preserves federal E-SIGN §101(c); exact federal consumer-consent implementation is not fully reverified in this pass.","Source / pinpoint":"S008 §26-6-30","Conditions, exceptions, currentness, confidence":"State-law preservation high; federal implementation held."},"coordinator_verification_status":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_SC-P3-C020","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P3-C020","Consequential assertion":"Mandatory contract language grants cancellation any time/any reason without penalty through 10 days' written notice, followed by refund of unexpended funds.","Source / pinpoint":"S001 §110(B)(7)","Conditions, exceptions, currentness, confidence":"High. Exact calendar endpoint not established."},"coordinator_verification_status":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_SC-P3-C021","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P3-C021","Consequential assertion":"§110(D) independently requires DMP cancellation on consumer request with at least ten days' notice and refund of all unexpended funds.","Source / pinpoint":"S001 §110(D)","Conditions, exceptions, currentness, confidence":"High."},"coordinator_verification_status":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_SC-P3-C022","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P3-C022","Consequential assertion":"This is a continuing termination right rather than a limited initial cooling-off window.","Source / pinpoint":"S001 §110(B)(7),(D)","Conditions, exceptions, currentness, confidence":"High textual characterization."},"coordinator_verification_status":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_SC-P3-C023","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P3-C023","Consequential assertion":"Statute does not enumerate a specific cancellation transmission channel; electronic notice may qualify as writing only subject to applicable UETA/contract requirements.","Source / pinpoint":"S001 §110; S008","Conditions, exceptions, currentness, confidence":"Qualified."},"coordinator_verification_status":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_SC-P3-C024","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P3-C024","Consequential assertion":"No Chapter7 counting rule establishing an exact calendar cancellation endpoint was located; litigation Rule6 is not imported without authority.","Source / pinpoint":"S001 §110; targeted counting-rule review","Conditions, exceptions, currentness, confidence":"Hold."},"coordinator_verification_status":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_SC-P3-C025","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P3-C025","Consequential assertion":"Cancellation refund is all unexpended funds, not automatically every historic payment or amount already remitted to creditors.","Source / pinpoint":"S001 §110(B)(7),(D)","Conditions, exceptions, currentness, confidence":"High for measure; earned-fee disputes remain separate."},"coordinator_verification_status":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_SC-P3-C026","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P3-C026","Consequential assertion":"§109(A)'s suitability failure can separately require return of the setup fee/account closure.","Source / pinpoint":"S001 §109(A)","Conditions, exceptions, currentness, confidence":"High condition; exact fee mechanics not revisited."},"coordinator_verification_status":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_SC-P3-C027","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P3-C027","Consequential assertion":"R.28-700 separately requires return of money received in violation of Act/regulation.","Source / pinpoint":"S003 B(4)","Conditions, exceptions, currentness, confidence":"Qualified currentness because Apr–Sep 2026 Register not freshly rechecked in P3."},"coordinator_verification_status":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_SC-P3-C028","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P3-C028","Consequential assertion":"No separate X-day deadline for paying the §110 unexpended-funds cancellation refund was located.","Source / pinpoint":"S001 §110","Conditions, exceptions, currentness, confidence":"Hold on payment timing."},"coordinator_verification_status":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_SC-P3-C029","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P3-C029","Consequential assertion":"Funds paid to licensee for creditor disbursement must enter a trust account established for debtors' benefit.","Source / pinpoint":"S001 §111(B)","Conditions, exceptions, currentness, confidence":"High."},"coordinator_verification_status":"targeted_correction_required","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_SC-P3-C030","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P3-C030","Consequential assertion":"Consumer-retained funds in a genuinely noncustodial negotiation model are not, solely by virtue of the negotiation, funds “paid to the licensee for disbursement.”","Source / pinpoint":"S001 §§101,111","Conditions, exceptions, currentness, confidence":"High textual distinction; actual account/control facts govern."},"coordinator_verification_status":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_SC-P3-C031","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P3-C031","Consequential assertion":"Control of funds can satisfy the DMP definition even without literal possession.","Source / pinpoint":"S001 §101(6)","Conditions, exceptions, currentness, confidence":"High. Third-party account arrangements require factual review."},"coordinator_verification_status":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_SC-P3-C032","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P3-C032","Consequential assertion":"Trust funds require debtor-level records, continuous segregation, and statutorily restricted use.","Source / pinpoint":"S001 §111(B)","Conditions, exceptions, currentness, confidence":"High."},"coordinator_verification_status":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_SC-P3-C033","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P3-C033","Consequential assertion":"Quarterly reporting of “charges deducted” does not, standing alone, establish authority to deduct every provider fee directly from the trust.","Source / pinpoint":"S001 §111","Conditions, exceptions, currentness, confidence":"Hold/interpretive caution."},"coordinator_verification_status":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_SC-P3-C034","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P3-C034","Consequential assertion":"Debtor payment must be deposited in trust no later than one business day after receipt.","Source / pinpoint":"S001 §111(B)(2)","Conditions, exceptions, currentness, confidence":"High."},"coordinator_verification_status":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_SC-P3-C035","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P3-C035","Consequential assertion":"Creditor funds must be disbursed no later than five business days after receipt.","Source / pinpoint":"S001 §111(B)(3)","Conditions, exceptions, currentness, confidence":"High."},"coordinator_verification_status":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_SC-P3-C036","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P3-C036","Consequential assertion":"Licensee must correct creditor payments misdirected due to its error.","Source / pinpoint":"S001 §111(B)(4)","Conditions, exceptions, currentness, confidence":"High."},"coordinator_verification_status":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_SC-P3-C037","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P3-C037","Consequential assertion":"On request, consumer gets signed/dated receipts or electronic account-status access.","Source / pinpoint":"S001 §111(B)(5)","Conditions, exceptions, currentness, confidence":"High."},"coordinator_verification_status":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_SC-P3-C038","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P3-C038","Consequential assertion":"Each trust account must be reconciled at least monthly against aggregate individual debtor escrow balances.","Source / pinpoint":"S001 §111(C)","Conditions, exceptions, currentness, confidence":"High. No tolerance/cure period located."},"coordinator_verification_status":"targeted_correction_required","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_SC-P3-C039","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P3-C039","Consequential assertion":"Quarterly accounting must itemize receipts, creditor payments, agreed payoff figures, deductions and amount held.","Source / pinpoint":"S001 §111(D)","Conditions, exceptions, currentness, confidence":"High."},"coordinator_verification_status":"targeted_correction_required","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_SC-P3-C040","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P3-C040","Consequential assertion":"Written-demand accounting is due within seven days, with no more than three required in each six-month period.","Source / pinpoint":"S001 §111(E)","Conditions, exceptions, currentness, confidence":"High text; exact calendar endpoint held."},"coordinator_verification_status":"targeted_correction_required","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_SC-P3-C041","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P3-C041","Consequential assertion":"R.28-700 requires record of the FDIC-insured institution where SC consumer funds are held and account number.","Source / pinpoint":"S003 D(1)(d)","Conditions, exceptions, currentness, confidence":"High as recordkeeping text; not overstated as standalone bank-eligibility clause."},"coordinator_verification_status":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_SC-P3-C042","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P3-C042","Consequential assertion":"Reviewed authorities do not establish blanket permission to delegate statutory custody to a third-party account administrator.","Source / pinpoint":"S001 §111; S003","Conditions, exceptions, currentness, confidence":"Unresolved. Agency/control and other-law analysis required."},"coordinator_verification_status":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_SC-P3-C043","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P3-C043","Consequential assertion":"Statute requires complete records and at least 3-year DMP retention; out-of-state records are subject to prompt DCA production requirements.","Source / pinpoint":"S001 §114","Conditions, exceptions, currentness, confidence":"High."},"coordinator_verification_status":"targeted_correction_required","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_SC-P3-C044","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P3-C044","Consequential assertion":"R.28-700 adds consumer/business record retention and permits equivalent accessible electronic records, subject to specific agency procedural requirements.","Source / pinpoint":"S003 D","Conditions, exceptions, currentness, confidence":"Qualified currentness as C027."},"coordinator_verification_status":"targeted_correction_required","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_SC-P3-C045","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P3-C045","Consequential assertion":"Act111 became effective December2, 2005.","Source / pinpoint":"S002","Conditions, exceptions, currentness, confidence":"High enactment history."},"coordinator_verification_status":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_SC-P3-C046","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P3-C046","Consequential assertion":"Online statutory Code says current through 2026 Session.","Source / pinpoint":"S005","Conditions, exceptions, currentness, confidence":"High as publisher status statement; online not official print edition."},"coordinator_verification_status":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_SC-P3-C047","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P3-C047","Consequential assertion":"R.28-700 history shows 2006 adoption, 2009 amendment, 2016 amendment.","Source / pinpoint":"S003 history","Conditions, exceptions, currentness, confidence":"High historical status."},"coordinator_verification_status":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_SC-P3-C048","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P3-C048","Consequential assertion":"P3 independently confirms no relevant Oct23 Register item, but does not freshly establish absence of every Apr–Sep2026 regulatory change.","Source / pinpoint":"S004, S012","Conditions, exceptions, currentness, confidence":"Explicit currentness hold."},"coordinator_verification_status":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_SC-P3-C049","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P3-C049","Consequential assertion":"2010 DCA interpretations remain posted but DCA warns interpretations may later be superseded.","Source / pinpoint":"S009–S011","Conditions, exceptions, currentness, confidence":"High status description; nonsupersession not certified."},"coordinator_verification_status":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"claim_id":"S_SC-P3-C050","area_numbers":[66],"area_assignment_method":"task_scope_fallback","researcher_record":{"Claim ID":"S_SC-P3-C050","Consequential assertion":"DCA checklist/FAQ are procedure/guidance rather than statutory permission.","Source / pinpoint":"S006–S007","Conditions, exceptions, currentness, confidence":"High source-characterization limit."},"coordinator_verification_status":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"}],"sources":[{"source_id":"S_SC-P3-S001","urls":["https://www.scstatehouse.gov/code/t37c007.php?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_SC-P3-S001","Issuer / title":"South Carolina General Assembly — Title 37, Chapter 7, Consumer Credit Counseling","Direct source":"Direct Chapter 7 text","Exact passage/read":"§§37-7-101, 102, 108–111, 114, 116; especially statutory lines reflected in turn574189view0, turn186003view0, turn253842view0, turn685233view1.","Legal/status characterization and limitations":"Current statutory compilation through 2026 Session per S005; online compilation not official printed Code. Freshly read."},"coordinator_verification_status":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"source_id":"S_SC-P3-S002","urls":["https://www.scstatehouse.gov/sess116_2005-2006/bills/607.htm?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_SC-P3-S002","Issuer / title":"South Carolina General Assembly — Act 111 of 2005 / S.607","Direct source":"Direct enrolled-act/history page","Exact passage/read":"Status and enactment history; became law without signature June 2, 2005; effective December 2, 2005.","Legal/status characterization and limitations":"Enacted historical foundation, not merely bill text. Freshly checked."},"coordinator_verification_status":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"source_id":"S_SC-P3-S003","urls":["https://www.scstatehouse.gov/coderegs/Chapter%2028.pdf?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_SC-P3-S003","Issuer / title":"South Carolina Code of Regulations — Chapter 28, R.28-700","Direct source":"Direct Chapter 28 PDF","Exact passage/read":"R.28-700(B), (D), history; PDF pp.35–38. Page images actually inspected as turn257930view0–turn257930view2.","Legal/status characterization and limitations":"Operative text in online compilation; history last amendment Feb.26, 2016. Compilation-currentness limitation in S004."},"coordinator_verification_status":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"source_id":"S_SC-P3-S004","urls":["https://www.scstatehouse.gov/coderegs/statmast.php?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_SC-P3-S004","Issuer / title":"South Carolina General Assembly — Code of Regulations status","Direct source":"Regulation compilation status","Exact passage/read":"Statement that compilation is current through State Register Vol.50 Issue3, March27, 2026; online disclaimer.","Legal/status characterization and limitations":"Currentness boundary; intervening Apr–Sep issues not freshly re-reviewed in this pass."},"coordinator_verification_status":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"source_id":"S_SC-P3-S005","urls":["https://www.scstatehouse.gov/code/statmast.php?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_SC-P3-S005","Issuer / title":"South Carolina General Assembly — Code of Laws status","Direct source":"Code status/disclaimer","Exact passage/read":"Current through 2026 Session and online/official-print disclaimer.","Legal/status characterization and limitations":"Supports statutory currentness, subject to site's stated limitation."},"coordinator_verification_status":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"source_id":"S_SC-P3-S006","urls":["https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Regulatory/Credit%20Counseling/Forms/Foreclosure%20Counseling%20Guidance.pdf?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_SC-P3-S006","Issuer / title":"South Carolina DCA — Foreclosure/Housing Counseling Compliance Guidance","Direct source":"Direct DCA checklist PDF","Exact passage/read":"Contract checklist and separate “if receiving consumer money for disbursement” requirements; page image inspected as turn746933view0.","Legal/status characterization and limitations":"Agency guidance, expressly not a substitute for law. Useful for DCA's general-vs-custodial contract distinction."},"coordinator_verification_status":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"source_id":"S_SC-P3-S007","urls":["https://consumer.sc.gov/consumer-faqs/credit-counseling-faqs?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_SC-P3-S007","Issuer / title":"South Carolina DCA — Credit Counseling FAQs","Direct source":"DCA Credit Counseling FAQ","Exact passage/read":"Creditor-consent form and paper-file instruction.","Legal/status characterization and limitations":"Agency procedural guidance; no separate legal effective date located."},"coordinator_verification_status":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"source_id":"S_SC-P3-S008","urls":["https://www.scstatehouse.gov/code/t26c006.php?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_SC-P3-S008","Issuer / title":"South Carolina General Assembly — Uniform Electronic Transactions Act, Title 26 Ch.6","Direct source":"Direct South Carolina UETA text","Exact passage/read":"§§26-6-30, 50, 70, 80: party agreement, e-record/e-signature effect, retainability, formatting, E-SIGN preservation.","Legal/status characterization and limitations":"Current state statute; used only for electronic-form questions."},"coordinator_verification_status":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"source_id":"S_SC-P3-S009","urls":["https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1003%20Assignment%20of%20Credit%20Counseling%20Contracts.pdf?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_SC-P3-S009","Issuer / title":"South Carolina DCA — Administrative Interpretation 7.108-1003","Direct source":"Direct interpretation PDF","Exact passage/read":"All 3 pages freshly inspected as page images turn780132view0–turn780132view2; prerequisite/assignment/compensation analysis.","Legal/status characterization and limitations":"Issued June29, 2010. Agency administrative interpretation, not regulation/court holding. Current index has supersession warning."},"coordinator_verification_status":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"source_id":"S_SC-P3-S010","urls":["https://consumer.sc.gov/sites/consumer/files/Documents/Business%20Resources%20Laws/Administrative%20Interpretations/Chapter%207/7.108-1001%20Credit%20Counselor%20-%20Budget%20Analysis.pdf?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_SC-P3-S010","Issuer / title":"South Carolina DCA — Administrative Interpretation 7.108-1001","Direct source":"Direct interpretation PDF","Exact passage/read":"Both pages freshly inspected as images turn780132view3–turn780132view4.","Legal/status characterization and limitations":"Issued April15, 2010. Same status limitation as S009."},"coordinator_verification_status":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"source_id":"S_SC-P3-S011","urls":["https://consumer.sc.gov/business-resourceslaws/administrative-interpretations/chapter-seven?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_SC-P3-S011","Issuer / title":"South Carolina DCA — Chapter Seven Administrative Interpretations index","Direct source":"DCA Chapter Seven interpretation index","Exact passage/read":"Current listing of 1001/1003 and warning regarding subsequent changes/supersession.","Legal/status characterization and limitations":"Current administrative index; listing ≠ formal nonsupersession determination."},"coordinator_verification_status":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"source_id":"S_SC-P3-S012","urls":["https://www.scstatehouse.gov/state_register.php?file=Sr50-10.pdf&first=FILE&pdf=1&utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_SC-P3-S012","Issuer / title":"South Carolina State Register Vol.50 Issue10","Direct source":"Direct October 23, 2026 issue PDF","Exact passage/read":"Publication metadata, contents, targeted searches for DCA/R.28-700/credit counseling; TOC page image inspected.","Legal/status characterization and limitations":"Published Oct.23, 2026. No relevant amendment found. Does not fill Apr–Sep PASS-03 gap."},"coordinator_verification_status":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"source_id":"S_SC-P3-S013","urls":["https://www.sccourts.org/media/opinions/HTMLFiles/SC/26648.htm?utm_source=chatgpt.com"],"researcher_record":{"Source ID":"S_SC-P3-S013","Issuer / title":"South Carolina Supreme Court — Lexington Law Firm v. SCDCA, Op.26648","Direct source":"Official court opinion page","Exact passage/read":"Used only as a bounded exemption cross-check: attorney category requires actual statutory conditions, not attorney branding alone.","Legal/status characterization and limitations":"Filed May12, 2009; controlling judicial authority on the exemption issue. No broader case-law pass performed."},"coordinator_verification_status":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"}],"coverage":[{"topic":"General written agreement requirement for compensated covered services","researcher_record":{"Question / component":"General written agreement requirement for compensated covered services","Status":"Answered","Claim IDs":"C005, C007–C009","Exact missing authority / next action":"Entity-specific coverage/exemption remains factual."},"table_index":2,"coverage_kind":"assigned_scope","coordinator_acceptance":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"topic":"Negotiation-only vs custodial DMP contract distinction","researcher_record":{"Question / component":"Negotiation-only vs custodial DMP contract distinction","Status":"Answered materially","Claim IDs":"C001–C002, C010–C011","Exact missing authority / next action":"Mixed/control models require agreement/account facts."},"table_index":2,"coverage_kind":"assigned_scope","coordinator_acceptance":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"topic":"Budget-analysis and pre-service documents","researcher_record":{"Question / component":"Budget-analysis and pre-service documents","Status":"Answered","Claim IDs":"C005–C006","Exact missing authority / next action":"Automated/unlicensed intake edge may need later authority for specific system design."},"table_index":2,"coverage_kind":"assigned_scope","coordinator_acceptance":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"topic":"Mandatory contract contents","researcher_record":{"Question / component":"Mandatory contract contents","Status":"Answered","Claim IDs":"C009–C010, C015–C016","Exact missing authority / next action":"Earlier fee-permission questions remain separate."},"table_index":2,"coverage_kind":"assigned_scope","coordinator_acceptance":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"topic":"Creditor participation/consent records","researcher_record":{"Question / component":"Creditor participation/consent records","Status":"Answered","Claim IDs":"C010, C012–C013","Exact missing authority / next action":"FAQ paper requirement remains agency guidance rather than statute."},"table_index":2,"coverage_kind":"assigned_scope","coordinator_acceptance":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"topic":"Executed contract copy delivery to consumer","researcher_record":{"Question / component":"Executed contract copy delivery to consumer","Status":"Partial / unresolved","Claim IDs":"C014","Exact missing authority / next action":"Check generally applicable SC consumer-contract law and any later DCA interpretation expressly requiring executed-copy delivery."},"table_index":2,"coverage_kind":"assigned_scope","coordinator_acceptance":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"topic":"Language/readability","researcher_record":{"Question / component":"Language/readability","Status":"Answered for specific statutory formatting; partial generally","Claim IDs":"C015","Exact missing authority / next action":"No general font/grade-level rule found; broader general-law requirements not investigated."},"table_index":2,"coverage_kind":"assigned_scope","coordinator_acceptance":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"topic":"Electronic signatures","researcher_record":{"Question / component":"Electronic signatures","Status":"Answered under SC UETA","Claim IDs":"C017","Exact missing authority / next action":"Provider implementation still requires actual party-consent evidence."},"table_index":2,"coverage_kind":"assigned_scope","coordinator_acceptance":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"topic":"Electronic delivery/retention","researcher_record":{"Question / component":"Electronic delivery/retention","Status":"Answered under SC UETA, federal overlay partial","Claim IDs":"C018–C019","Exact missing authority / next action":"Current federal E-SIGN §101(c) implementation must be independently checked before deploying electronic-only consumer disclosures."},"table_index":2,"coverage_kind":"assigned_scope","coordinator_acceptance":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"topic":"Cancellation right","researcher_record":{"Question / component":"Cancellation right","Status":"Answered","Claim IDs":"C020–C023","Exact missing authority / next action":"Method-specific implementation may depend on UETA/contract."},"table_index":2,"coverage_kind":"assigned_scope","coordinator_acceptance":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"topic":"Exact 10-day calendar computation","researcher_record":{"Question / component":"Exact 10-day calendar computation","Status":"Unresolved","Claim IDs":"C024","Exact missing authority / next action":"Locate controlling SC authority applying a counting rule to §37-7-110 private notice; then apply actual transmission/receipt facts."},"table_index":2,"coverage_kind":"assigned_scope","coordinator_acceptance":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"topic":"Cooling-off period","researcher_record":{"Question / component":"Cooling-off period","Status":"Answered: no initial-only cooling-off rule located; continuous termination instead","Claim IDs":"C022","Exact missing authority / next action":"Broader generally applicable rescission regimes outside Chapter7 not investigated."},"table_index":2,"coverage_kind":"assigned_scope","coordinator_acceptance":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"topic":"Cancellation refund measure","researcher_record":{"Question / component":"Cancellation refund measure","Status":"Answered","Claim IDs":"C025","Exact missing authority / next action":"Disputed earned fees need fee-specific authority/facts."},"table_index":2,"coverage_kind":"assigned_scope","coordinator_acceptance":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"topic":"Cancellation refund payment deadline","researcher_record":{"Question / component":"Cancellation refund payment deadline","Status":"Unresolved","Claim IDs":"C028","Exact missing authority / next action":"Locate statute/regulation/formal interpretation/case prescribing payment timing, if any."},"table_index":2,"coverage_kind":"assigned_scope","coordinator_acceptance":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"topic":"§109 conditional setup refund","researcher_record":{"Question / component":"§109 conditional setup refund","Status":"Answered at structural level only","Claim IDs":"C026","Exact missing authority / next action":"Prior fee/currentness/sequencing holds remain."},"table_index":2,"coverage_kind":"assigned_scope","coordinator_acceptance":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"topic":"Trust-account trigger","researcher_record":{"Question / component":"Trust-account trigger","Status":"Answered","Claim IDs":"C029–C031","Exact missing authority / next action":"Actual third-party/control structures remain factual/legal dependency."},"table_index":2,"coverage_kind":"assigned_scope","coordinator_acceptance":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"topic":"Segregation and permissible use","researcher_record":{"Question / component":"Segregation and permissible use","Status":"Answered, with fee-deduction hold","Claim IDs":"C032–C033","Exact missing authority / next action":"Need authoritative interpretation whether/when provider compensation may be withdrawn directly from statutory trust."},"table_index":2,"coverage_kind":"assigned_scope","coordinator_acceptance":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"topic":"One-business-day deposit","researcher_record":{"Question / component":"One-business-day deposit","Status":"Answered","Claim IDs":"C034","Exact missing authority / next action":"Exact calendar date requires receipt timestamp and applicable holiday/business-day facts."},"table_index":2,"coverage_kind":"assigned_scope","coordinator_acceptance":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"topic":"Five-business-day creditor distribution","researcher_record":{"Question / component":"Five-business-day creditor distribution","Status":"Answered","Claim IDs":"C035","Exact missing authority / next action":"Same factual calendar dependency."},"table_index":2,"coverage_kind":"assigned_scope","coordinator_acceptance":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"topic":"Misdirected payments","researcher_record":{"Question / component":"Misdirected payments","Status":"Answered","Claim IDs":"C036","Exact missing authority / next action":"Full loss/remedy architecture deferred."},"table_index":2,"coverage_kind":"assigned_scope","coordinator_acceptance":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"topic":"Consumer receipts/electronic account access","researcher_record":{"Question / component":"Consumer receipts/electronic account access","Status":"Answered","Claim IDs":"C037","Exact missing authority / next action":"Technical standard for electronic access not specified in provision."},"table_index":2,"coverage_kind":"assigned_scope","coordinator_acceptance":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"topic":"Monthly reconciliation","researcher_record":{"Question / component":"Monthly reconciliation","Status":"Answered","Claim IDs":"C038","Exact missing authority / next action":"Cure deadline/tolerance for discrepancies not found."},"table_index":2,"coverage_kind":"assigned_scope","coordinator_acceptance":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"topic":"Quarterly accounting","researcher_record":{"Question / component":"Quarterly accounting","Status":"Answered","Claim IDs":"C039","Exact missing authority / next action":"Precise treatment of disputed deductions remains held."},"table_index":2,"coverage_kind":"assigned_scope","coordinator_acceptance":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"topic":"Demand accounting within seven days","researcher_record":{"Question / component":"Demand accounting within seven days","Status":"Answered textually","Claim IDs":"C040","Exact missing authority / next action":"Exact calendar endpoint requires counting rule/receipt facts."},"table_index":2,"coverage_kind":"assigned_scope","coordinator_acceptance":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"topic":"FDIC-insured institution requirement","researcher_record":{"Question / component":"FDIC-insured institution requirement","Status":"Partial/qualified","Claim IDs":"C041","Exact missing authority / next action":"Regulation phrases this as required record about institution; locate any separate affirmative depository-account rule if stronger proposition is needed."},"table_index":2,"coverage_kind":"assigned_scope","coordinator_acceptance":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"topic":"Third-party account administrator authority","researcher_record":{"Question / component":"Third-party account administrator authority","Status":"Unresolved","Claim IDs":"C042","Exact missing authority / next action":"Need contract/control facts plus any DCA interpretation/order and potentially separate money-transmission/banking law."},"table_index":2,"coverage_kind":"assigned_scope","coordinator_acceptance":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"topic":"Statutory record retention","researcher_record":{"Question / component":"Statutory record retention","Status":"Answered","Claim IDs":"C043","Exact missing authority / next action":"Enforcement/exam architecture deferred."},"table_index":2,"coverage_kind":"assigned_scope","coordinator_acceptance":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"topic":"Regulatory record retention/electronic records","researcher_record":{"Question / component":"Regulatory record retention/electronic records","Status":"Answered subject to currentness hold","Claim IDs":"C044, C048","Exact missing authority / next action":"Freshly check intervening Apr–Sep2026 Register issues before formal current-law reliance on regulation."},"table_index":2,"coverage_kind":"assigned_scope","coordinator_acceptance":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"topic":"Statutory enactment/currentness","researcher_record":{"Question / component":"Statutory enactment/currentness","Status":"Answered","Claim IDs":"C045–C046","Exact missing authority / next action":"Official printed-code caveat preserved."},"table_index":2,"coverage_kind":"assigned_scope","coordinator_acceptance":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"topic":"Regulation currentness through Oct24 2026","researcher_record":{"Question / component":"Regulation currentness through Oct24 2026","Status":"Partial","Claim IDs":"C047–C048","Exact missing authority / next action":"Apr–Sep 2026 State Register issues not freshly re-read in this pass."},"table_index":2,"coverage_kind":"assigned_scope","coordinator_acceptance":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"topic":"2010 interpretations present status","researcher_record":{"Question / component":"2010 interpretations present status","Status":"Partial","Claim IDs":"C049","Exact missing authority / next action":"DCA itself warns to confirm supersession before formal reliance."},"table_index":2,"coverage_kind":"assigned_scope","coordinator_acceptance":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"topic":"Provider authorization","researcher_record":{"Question / component":"Provider authorization","Status":"Excluded / not established","Claim IDs":"—","Exact missing authority / next action":"Requires actual current license/status evidence in separate component."},"table_index":2,"coverage_kind":"assigned_scope","coordinator_acceptance":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"topic":"Complete fee architecture","researcher_record":{"Question / component":"Complete fee architecture","Status":"Excluded from PASS-03","Claim IDs":"—","Exact missing authority / next action":"PASS-01/PASS-02 holds remain; not reopened."},"table_index":2,"coverage_kind":"assigned_scope","coordinator_acceptance":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"topic":"Bonds/insurance","researcher_record":{"Question / component":"Bonds/insurance","Status":"Excluded except where custody concept intersects","Claim IDs":"—","Exact missing authority / next action":"Separate required pass."},"table_index":2,"coverage_kind":"assigned_scope","coordinator_acceptance":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"topic":"Complaint/exam/enforcement/private remedies","researcher_record":{"Question / component":"Complaint/exam/enforcement/private remedies","Status":"Excluded except contract voidness/direct return rights","Claim IDs":"C016","Exact missing authority / next action":"Separate pass required."},"table_index":2,"coverage_kind":"assigned_scope","coordinator_acceptance":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"topic":"Full collection/litigation/limitations/debtor exemptions/secured debt/sector/local/tribal/case law","researcher_record":{"Question / component":"Full collection/litigation/limitations/debtor exemptions/secured debt/sector/local/tribal/case law","Status":"Open / excluded","Claim IDs":"—","Exact missing authority / next action":"Separate parent investigations required."},"table_index":2,"coverage_kind":"assigned_scope","coordinator_acceptance":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"},{"topic":"State/A066 acceptance","researcher_record":{"Question / component":"State/A066 acceptance","Status":"Not performed","Claim IDs":"—","Exact missing authority / next action":"No implication of completion."},"table_index":2,"coverage_kind":"assigned_scope","coordinator_acceptance":"selected_scoped_review_with_evidence_limits_see_review","coordinator_review":"[internal evidence reference]"}],"annotations":{},"corrections":[],"resolved_corrections":[],"review_history":[]}